- 29 - Secretary as to which returns * * * are made under this title.” Respondent cites, and we have discovered, no authority to suggest that the unsigned copy of petitioner’s 1995 married filing separate return should be considered a valid return for purposes of section 6201(a). Cf. sec. 6065 (generally requiring any return to contain or be verified by a written declaration that it is made under penalties of perjury); Dixon v. Commissioner, 28 T.C. 338, 348 (1957) (“The respondent does not cite any decision where * * * it was held that an unsigned and otherwise unverified duplicate copy of a purported income tax return was held to be the return required by statute and was to be given effect as such”). An unsigned return “is no return at all.” Vaira v. Commissioner, 52 T.C. 986, 1005 (1969), affd. on this issue, revd. and remanded on other grounds 444 F.2d 770 (3d Cir. 1971); see Borgeson v. United States, 757 F.2d 1071 (10th Cir. 1985). A signature on a letter attached to the return cannot be considered an imputed signature on the return itself. Richardson v. Commissioner, 72 T.C. 818, 824 (1980). Moreover, even if we were to assume, arguendo, that the IRS accepted petitioner’s unsigned copy of the 1995 married filing separate return and processed it, such acceptance would not cure an invalid return. See Olpin v. Commissioner, 270 F.3d at 1301; Dixon v. Commissioner, supra at 347.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 NextLast modified: November 10, 2007