- 6 - 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 receivedPage: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007