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their Forms 4868 or that they considered petitioner’s partnership
draws or income. For 1992, for which petitioners estimated that
their tax liability was two-thirds of what they later reported on
their Form 1040, there is no evidence that the error related to
an unusual item. Thus, petitioners have not shown that they used
a reasonable method to estimate their tax liabilities when they
filed the Forms 4868 for the years in issue.
Petitioners contend that respondent should have informed
them in a timely manner that their Forms 4868 were invalid. We
disagree. Holding otherwise would unreasonably require the
Commissioner to conduct a detailed examination of every extension
request before approving it. Crocker v. Commissioner, supra at
911.
Petitioners did not properly estimate their tax liability on
the Forms 4868 they filed for 1990, 1991, and 1992. Thus, we
hold that those forms are invalid. See id. at 910.
B. Whether Petitioners Are Liable for Additions to Tax for
Failure To Timely File Under Section 6651(a)
Section 6651(a)(1) provides for an addition to tax up to 25
percent for failure to timely file Federal income tax returns
unless the taxpayer shows that such failure was due to reasonable
cause and not willful neglect. United States v. Boyle, 469 U.S.
241, 245 (1985); Baldwin v. Commissioner, 84 T.C. 859, 870
(1985); Davis v. Commissioner, 81 T.C. 806, 820 (1983), affd.
without published opinion 767 F.2d 931 (9th Cir. 1985).
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