Cliff Connors - Page 24

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          return, in the context of section 6651(a)(2) and (g)(2), “must be           
          subscribed, it must contain sufficient information from which to            
          compute the taxpayer’s tax liability, and the return form and any           
          attachments must purport to be a ‘return’.”  Spurlock v.                    
          Commissioner, supra; see also Cabirac v. Commissioner, 120 T.C.             
          163, 170-171 (2003).  Respondent has satisfied the requirements             
          under sections 6651(a)(2), (g)(2), and 6020(b).  Because                    
          petitioner has failed to allege any specific facts with respect             
          to the addition to tax, and because liability for the addition to           
          tax was deemed admitted pursuant to Rule 90, the addition to tax            
          under section 6651(a)(2) is sustained.                                      
          Filing Status                                                               
               Section 1(d) provides that every married individual who does           
          not make a single return jointly with his spouse has a filing               
          status of married filing separately.  Petitioner and Mrs. Connors           
          did not file a joint return for 2002, and there is no reliable              
          evidence that they ever intended to file a joint return for 2002.           
          Therefore, petitioner’s filing status for 2002 is married filing            
               We have considered the arguments of the parties that were              
          not specifically addressed in this opinion.  Those arguments are            
          either without merit or irrelevant to our decision.                         

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