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board's activities during those years were similar to its ac-
tivities during 1989 and 1990. During each of the years 1985
through 1988, petitioner spent substantially less than 500 hours
in attending to matters relating to Crestwood Association owners'
operations and lodge operations and spent less time in those
operations than he spent in those operations during each of the
years at issue.
Petitioners' Federal Income Tax Returns
For the years 1987 and 1988, petitioners' Federal income tax
returns reflected tax liabilities of $16,405 and $62,341, respec-
tively.
Petitioners filed a Form 4868, Application for Automatic
Extension of Time to File U.S. Individual Income Tax Return
(application for automatic extension) dated April 13, 1990,
requesting a four-month extension of time to file their Federal
income tax return for 1989 (1989 return). Line 1 of the applica-
tion for automatic extension that petitioners filed for 1989
provided as follows:
Total tax liability for 1989. This is the amount you
expect to enter on line 24 of Form 1040A, or line 55 of
Form 1040. If you do not expect to owe tax, enter zero
(-0-) . . . . . . . . . . . . . . . . . . . . . . . . .
Caution: You MUST enter an amount on line 1 or your
extension will be denied. You can estimate this
amount; but be as exact as you can with the information
you have. If we later find that your estimate was not
reasonable, the extension will be null and void.
Petitioners' application for automatic extension for 1989 indi-
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