Marvin W. and Kathryn A. McPike - Page 15

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          liability is insufficient to conclude that the estimate was                 
          improper.  Id. at 906.                                                      
               A taxpayer is treated as having "properly estimated" his tax           
          liability, within the meaning of section 1.6081-4(a)(4), Income             
          Tax Regs., when he makes a bona fide and reasonable estimate of             
          his tax liability based on the information available to him at              
          the time he makes his request for an extension.  Crocker v.                 
          Commissioner, supra at 908.  Petitioners estimated their tax                
          liability to be $5,077 at the time they filed their extension               
          request.  Their 1984 Federal income tax return reported an income           
          tax liability in the same amount.  Ultimately, after the issuance           
          of the notice of deficiency and disallowance of credits and                 
          deductions reported on the 1984 Federal income tax return,                  
          petitioners' true income tax liability was determined to be                 
          $16,510.                                                                    
               Petitioners argue that the Form 4868 was prepared by                   
          Lukensow and that they paid the amount of tax they believed to be           
          due for 1984.  It is the taxpayer's obligation to supply his                
          accountant with complete and accurate records from which to make            
          a reasonable estimate of tax liability.  Estate of Duttenhofer v.           
          Commissioner, 49 T.C. 200, 205 (1967), affd. per curiam 410 F.2d            
          302 (6th Cir. 1969).  Petitioners located, gathered, and supplied           
          all of their 1984 income tax information to Lukensow.                       
               In the previous section of this opinion, we held that                  
          petitioners were negligent in claiming deductions and investment            




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