Lesson From The Tax Court: Don’t Confuse Dummy Returns With Substitutes For Returns

(TaxProf Blog) - When a taxpayer fails to file a return, even after being reminded to do so, the IRS can simply send the taxpayer a Notice of Deficiency (NOD)...or the IRS can follow the §6020 Substitute For Return (SFR) process whereby it creates a return for the taxpayer either with or without the taxpayer’s cooperation.

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