- 8 - 120 T.C. 163, 169 (2003) (“The majority of courts, including this Court, have held that, generally, a return that contains only zeros is not a valid return.”);7 see also Rev. Rul. 2004-34, 2004-1 C.B. 619. Petitioner has not presented any evidence to suggest that her filing of a “zero return” was due to reasonable cause. In that regard, we note that petitioner filed her “zero return” after purchasing and reading the works of Irwin Schiff, a known tax protester. Petitioner’s reliance on the frivolous arguments of a known tax protester, which have been rejected repeatedly by this Court and others, was not reasonable and will not shield her from the imposition of an addition to tax under section 6651(a)(1). See Lopez v. Commissioner, T.C. Memo. 2001-211 (rejecting an argument in reliance on Irwin Schiff’s works in an attempt to avoid the imposition of additions to tax and 7 An appeal in this case would normally lie in the Court of Appeals for the Fourth Circuit, absent a stipulation to the contrary. Although we are not aware of any ruling by the Court of Appeals for the Fourth Circuit on this issue, a majority of Courts of Appeals have held that a return devoid of financial information is not a valid return. See United States v. Mosel, 738 F.2d 157, 158 (6th Cir. 1984); United States v. Grabinski, 727 F.2d 681, 687 (8th Cir. 1984); United States v. Rickman, 638 F.2d 182, 184 (10th Cir. 1980); United States v. Moore, 627 F.2d 830, 834 (7th Cir. 1980); United States v. Smith, 618 F.2d 280, 281 (5th Cir. 1980). The decision of the Court of Appeals for the Ninth Circuit in United States v. Long, 618 F.2d 74, 75-76 (9th Cir. 1980), insofar as it is to the contrary, represents a minority view that we need not follow in this case.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: March 27, 2008