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evidence a reasonable attempt to file a tax return under the tax
laws. See Williams v. Commissioner, 114 T.C. 136, 143 (2000).
Additionally, the Form 1040 filed by petitioner did not
contain sufficient information to constitute a valid return. We
have held that the attachment of a Form W-2 does not substitute
for the disclosure on the form itself of income, deductions,
credits, and tax liability. Reiff v. Commissioner, 77 T.C. 1169,
1178 (1981); see Beard v. Commissioner, supra at 779. Ignoring
the Form W-2, the Form 1040 reports zero income, deductions,
credits, and tax liability. We have consistently held that a
zero tax return is not a valid tax return because it does not
contain sufficient information for respondent to calculate and
assess a tax liability. See Cabirac v. Commissioner, supra at
169; Cline v. Commissioner, T.C. Memo. 1982-44; see also United
States v. Rickman, 638 F.2d 182, 184 (10th Cir. 1980); United
States v. Porth, 426 F.2d 519, 523 (10th Cir. 1970).4
We conclude that petitioner’s tax return did not constitute
a valid return for section 6651(a)(1) purposes. Further,
petitioner did not provide evidence that his failure to file a
valid tax return was because of reasonable cause and not because
4 We note that the Court of Appeals for the Ninth Circuit
has held that a zero tax return is a valid tax return. United
States v. Long, 618 F.2d 74, 75-76 (9th Cir. 1980). The Court of
Appeals for the Tenth Circuit, the court to which this case is
appealable, has expressly disagreed with the decision in Long.
United States v. Rickman, 638 F.2d 182, 184 (10th Cir. 1980).
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