Mr. Q owns a building company and hires subcontractors to assist with the work. In tax years 2012–2014, he filed a Form 1099 for each worker earning more than $600 but did not provide taxpayer ID numbers or social security numbers on most of the forms. While he was required to withhold tax on the payments to the contractors and to report that on Form 945 (Annual Return of Withheld Income Tax), he did not do so. In 2020, the IRS assessed Mr. Q with more than $100,000 of additional tax plus penalties and interest for failing to withhold tax from the workers in tax years 2012–2014. Mr. Q contested the assessment arguing that his filing of 1099s constituted a return for purposes of the statute of limitations and accordingly the period for the IRS to assess penalties had passed. Is there support for Mr. Q’s argument?