- 5 - purported return for 2001 is unsigned, and the purported return for 2002 contains only zeros in the entries for income. Neither constitutes a return for purposes of section 6651(a)(1). See United States v. Moore, 627 F.2d 830, 835 (7th Cir. 1980); Cabirac v. Commissioner, 120 T.C. 163, 168-170 (2003); Thompson v. Commissioner, 78 T.C. 558, 562-563 (1982); Vaira v. Commissioner, 52 T.C. 986, 1004-1005 (1969), revd. on other grounds 444 F.2d 770 (3d Cir. 1971). We conclude that petitioner did not file returns in 2001 or 2002 for purposes of section 6651(a)(1). As petitioner has produced no evidence that she had reasonable cause for her failure to file, we sustain respondent’s determination that petitioner is liable for additions to tax under section 6651(a)(1) for 2001 and 2002. Section 6673 Penalty Respondent has moved for a penalty under section 6673(a)(1). Whenever it appears to the Court that proceedings have been instituted or maintained primarily for delay or the taxpayer’s position in such proceedings is frivolous or groundless, the Court may require the taxpayer to pay a penalty not in excess of $25,000. Sec. 6673(a)(1). 1(...continued) Individual Income Tax Return, followed by a partially filled out Form 1040, U.S. Individual Income Tax Return. Thus, on its face each document appears to be a request for an extension rather than a return.Page: Previous 1 2 3 4 5 6 7 NextLast modified: November 10, 2007