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Petitioners relied on the automatic extensions for the years
in issue as a defense to the addition to tax for failure to
timely file under section 6651(a). Reliance on an automatic
extension is not reasonable cause for a taxpayer's failure to
timely file a return if the taxpayer failed to properly estimate
his or her tax liability in requesting the extension. Crocker v.
Commissioner, 92 T.C. 899 (1989).
We conclude that petitioners are liable for the additions to
tax under section 6651(a).
C. Whether Petitioners Are Liable for the Accuracy-Related
Penalty Under Section 6662(a)
Respondent determined that petitioners are liable for the
accuracy-related penalty for 1990 under section 6662(a) and (c)
because of negligence (see note 1 to table, p. 2). Taxpayers are
liable for a penalty equal to 20 percent of the portion of the
underpayment to which section 6662 applies. Sec. 6662(a). For
purposes of section 6662(a), negligence includes any failure to
make a reasonable attempt to comply with the provisions of the
Internal Revenue Code. Sec. 6662(c).
Negligence frequently involves a failure to report income
or an overstatement of deductions. Marcello v. Commissioner, 380
F.2d 509 (5th Cir. 1967), affg. T.C. Memo. 1964-303; Beus v.
Commissioner, 261 F.2d 176 (9th Cir. 1958), affg. 28 T.C. 1133
(1957); Estate of Mason v. Commissioner, 64 T.C. 651 (1975),
affd. 566 F.2d 2 (6th Cir. 1977). Petitioners did not explain
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