T.C. Memo. 2004-124
UNITED STATES TAX COURT
MICHAEL STEIN, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 10970-01L. Filed May 24, 2004.
Michael Stein, pro se.
John Aletta, for respondent.
MEMORANDUM OPINION
BEGHE, Judge: Petitioner failed to file timely Federal
income tax returns for 1992, 1993, and 1994. Respondent filed
“substitutes for return”1 (SFRs) for those years, mailed
1The Commissioner has previously represented to this Court
that the term “substitute for return” (SFR) is a term used by the
Commissioner for returns or partial returns prepared by the
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