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symbols. Notably missing is anything resembling a Form 1040 or a
transcript of account showing the entry of data used to establish
the taxpayer’s IRS account, as claimed in the certification. In
a separate exhibit, respondent offered a printout of petitioner’s
IRS account as evidence that an assessment had not been made in
this case. Though this printout appears to reflect an SFR entry
on July 26, 2004, with an accompanying document locator number,
this printout lacks any pertinent information besides the
taxpayer’s Social Security number. Even if we were to reasonably
infer that the administrative SFR entry corresponds to a dummy
return for petitioner for the year 2002, see Phillips v.
Commissioner, supra at 437, we cannot say that these documents
meet the requirements of a section 6020(b) return.
An assortment of documents spread throughout the record,
though altogether providing the requisite information, does not
constitute a return. Cabirac v. Commissioner, supra at 172.
Furthermore, simply being able to determine the tax liability
from respondent’s files does not accord them status as a return.
Spurlock v. Commissioner, T.C. Memo. 2003-124. Indeed, if such a
lack of formality were to prevail, the section 6651(a)(2) penalty
would be appropriate in every case by virtue of sections 6020(b)
and 6651(g). Cabirac v. Commissioner, supra at 172.
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