What is the test for making a return under the Revenue and Customs Act?

MultiRegion, United States of America

The following excerpt is from Wertheim v. C.I.R., 981 F.2d 1261 (9th Cir. 1992):

However, "[i]f any person fails to make any return required by any internal revenue law or regulation ..., the Secretary shall make such return from his own knowledge and from such information as he can obtain through testimony or otherwise." 26 U.S.C. 6020(b); see Roat v. Commissioner, 847 F.2d 1379, 1382 n. 1 (9th Cir.1988).

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