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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 reasonably
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