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Return, a revenue agent’s report containing sufficient
information to calculate petitioner’s tax liability, a Form 4549,
Income Tax Examination Changes, and a Form 13496, IRC Section
6020(b) Certification, signed by respondent’s examination
operations manager combined to yield a substitute return. An
unsubscribed Form 1040 along with the attached revenue agent’s
report containing all relevant information also qualified as a
substitute return in Millsap v. Commissioner, supra. Finally, in
Conovitz v. Commissioner, T.C. Memo. 1980-22, we held that a Form
1040 with the taxpayer’s name, address, and Social Security
number plus a Form 1902-E, Explanation of Adjustments, showing
petitioner’s wages, standard deduction, and exemption that was
prepared at the same time and in conjunction with the Form 1040
was a substitute return.
In contrast to the above cases, we have declined to accept
other combinations of evidence as substitute returns for section
6651(a)(2) purposes. A record containing a substantially blank
and unsubscribed Form 1040 filed February 23, 2000, a notice of
proposed adjustments dated May 31, 2000, and a revenue agent’s
report attached to the notice, which contained sufficient
information from which to calculate petitioner’s tax liability,
nevertheless did not meet the standard in Cabirac v.
Commissioner, supra. In Spurlock v. Commissioner, T.C. Memo.
2003-124, an untranslatable computer printout noting a received
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