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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.
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