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that the return is true, correct, and complete. For example, the
mere addition near the jurat of the words "under protest" will
not invalidate the return. See McCormick v. Peterson, 73 AFTR 2d
94-597, 94-1 USTC par. 50,026 (E.D.N.Y. 1993); see also Todd v.
United States, 849 F.2d 365, 367 (9th Cir. 1988) (addition of
words "signed involuntarily under penalty of statutory
punishment" below the jurat did not invalidate return). However,
where the purported return refers to and includes an accompanying
statement that disclaims liability for the tax reported on the
return or appears to contradict the declarations in the jurat,
the return is invalid, as the accompanying statement vitiates the
jurat. Williams v. Commissioner, 114 T.C. 136 (2000); Sloan v.
Commissioner, supra. Doubts regarding whether the accompanying
statement has qualified the jurat so as to invalidate the return
are resolved in the Commissioner's favor. Sloan v. Commissioner,
53 F.3d 799, 800 (7th Cir. 1995), affg. 102 T.C. 137.
For example, in Sloan, the purported returns contained the
following statement after the preprinted jurat, immediately above
the taxpayer's signature, "Denial and Disclaimer attached as part
of this Form". Attached to the purported returns was the
following statement:
"I submit this 'Denial and Disclaimer' as an attachment
to the IRS Form 1040 for the year stated above. I deny
that I am liable or made liable for any '1040 income
tax' for the above stated year. * * * My signature on
the form is not an admission of jurisdiction or
submission to subject status. I 'disclaim liability'
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