- 13 - issue and that he received from the pension distribution in 1990. Those amounts would have enabled petitioners to estimate their tax liability for the years in issue far more accurately than they did. Petitioner’s draws and the income that he reported from his law firm are as follows: Income From Year Draws Law Firm 1990 $106,250 $110,615 1991 93,000 105,322 1992 144,120 141,244 Petitioners did not follow the instructions on the Forms 4868 for 1990. Line 1 of Form 4868 calls for the total tax liability for 1990 that the taxpayer expects to enter on his or her individual income tax return. For 1990, petitioners did not make an entry on line 1 of Form 4868. One could infer that petitioners made a tax liability estimate of $6,000 based on the Form 4868 by adding the balance due ($1,200) to the total payments and credits ($4,800). However, $6,000 would not have been a reasonable estimate; $6,000 is less than one-fifth of the 1990 tax liability ($31,856) to which they later agreed. For 1991, petitioners’ estimate of their tax was about two-fifths of their liability as reported on their income tax return, and for 1992, their estimate was about two-thirds of their liability as reported on their income tax return. See table at par. B-5 of the Findings of Fact, p. 9. Petitioners did not make a bona fide attempt to base their estimate on information that was reasonablyPage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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