William O. Harrison - Page 29

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             "are not supported by any evidence."  To find otherwise,                 
             according to respondent, the Court would have to disregard               
             "petitioners' past conduct in filing extensions and failing              
             to make proper estimated tax payments" and the Court would               
             have to "accept the unsupported testimony of petitioners                 
             and their representatives."  Finally, respondent argues                  
             that petitioners cannot avoid the delinquency addition                   
             by claiming reasonable reliance on their accountants.                    
             According to respondent, petitioners have not shown "'that               
             the advisor had sufficient knowledge of the taxpayer's                   
             relevant financial circumstances to make an informed                     
             decision.'" (quoting Stovall v. Commissioner, T.C. Memo.                 
             1983-450, affd. 762 F.2d 891 (11th Cir. 1985)).                          
                  Respondent's position in this case places great                     
             emphasis on "the past history of petitioners' failure                    
             to make proper estimates of Federal tax liability".                      
             However troubling we find that history to be, we are                     
             mindful of our opinion in Crocker v. Commissioner, 92 T.C.               
             899, 906 (1989), which states that "a mere comparison of                 
             estimated tax liabilities with true tax liabilities will                 
             not reveal whether petitioners' estimates were 'proper.'"                
             In that case, we continued with the following:                           

                  An estimate is no more than that.  It is, "A                        
                  valuing or rating by the mind, without actually                     






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