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purposes if: (1) It contains sufficient data to calculate tax
liability; (2) it purports to be a return; (3) it represents an
honest and reasonable attempt to satisfy the requirements of the
tax law; and (4) it is executed under penalties of perjury. The
majority of courts, including this Court, have held that,
generally, a return that contains only zeros is not a valid
return. See United States v. Mosel, 738 F.2d 157 (6th Cir.
1984); United States v. Grabinski, 727 F.2d 681 (8th Cir. 1984);
United States v. Rickman, 638 F.2d 182 (10th Cir. 1980); United
States v. Moore, 627 F.2d 830 (7th Cir. 1980); United States v.
Smith, 618 F.2d 280 (5th Cir. 1980); Turner v. Commissioner, T.C.
Memo. 2004-251; Lee v. Commissioner, T.C. Memo. 1986-294; Cline
v. Commissioner, T.C. Memo. 1982-44; Teixera v. United States, 85
AFTR 2d 1657, 2000-1 USTC par. 50,479 (D.S.C. 2000). For
example, in United States v. Moore, supra at 835, the Court of
Appeals for the Seventh Circuit noted that a tax might
conceivably be calculated on the basis of the zero entries;
however, “it is not enough for a form to contain some income
information; there must also be an honest and reasonable intent
to supply the information required by the tax code.” See also
United States v. Mosel, supra at 158. In United States v.
Edelson, 604 F.2d 232, 234 (3d Cir. 1979), the Court of Appeals
for the Third Circuit stated: “it is now well established that
tax forms that do not contain financial information upon which a
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