Persons Required to Make Returns of Income (Required v. Not Required)

ID: CCA_2010100515555542 Number: 201042037
Release Date: 10/22/2010
Office: ---
UILC: 6012.00-00
From: ---
Sent: Tuesday, October 05, 2010 3:55:56 PM
To: ---
Cc: ---
Subject: as requested
---
On September 14, I sent an email to several attorneys in --- confirming that Hagger, 308 US 389, is good law and that we are still following it; so that a taxpayer would be considered to have filed a superseding "first" return" (which would be the original return) as long as it's filed by the extended due date. I think we're on pretty solid ground that if it is after the extended due date, all bets are off.
We also have a couple revenue rulings that follow it in spirit. See RR 78-256, RR 83-36, RR 86-58.
Let me know if you need anything further.