Mark J. and Deborah A. Hanna - Page 9

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          petitioners computed their tax based on past income history or              
          that it was consistent with the computation of tax for any prior            
          year.                                                                       
               Respondent appropriately voided petitioners’ 1989 extension            
          because petitioners failed to estimate properly their tax                   
          liability, as required under Crocker v. Commissioner, supra.                
          Thus, respondent’s determination that petitioners are liable for            
          the section 6651(a)(1) addition to tax for 1989 will be                     
          sustained.                                                                  
          Section 6653(a)(1)(A) and (B) and Section 6653(a)(1)                        
               Respondent determined that petitioners are liable for the              
          section 6653(a)(1)(A) and (B) addition to tax for 1987 and the              
          section 6653(a)(1) addition to tax for 1988.  Section                       
          6653(a)(1)(A) and section 6653(a)(1) impose an addition to tax              
          equal to 5 percent of the underpayment if any part of the                   
          underpayment is due to negligence or intentional disregard of               
          rules or regulations.  Section 6653(a)(1)(B) imposes an addition            
          to tax equal to 50 percent of the interest due on the portion of            
          the underpayment attributable to negligence.  Negligence is                 
          defined as a lack of due care or failure to do what a reasonable            
          and ordinarily prudent person would do under the circumstances.             
          Leuhsler v. Commissioner, 963 F.2d 907, 910 (6th Cir. 1992),                
          affg. T.C. Memo. 1991-179; Neely v. Commissioner, 85 T.C. 934,              
          947-948 (1985).  Petitioners bear the burden of proving that                






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