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valid. See Crocker v. Commissioner, supra at 911.
In their respective applications for automatic extension for
1989 and 1990, petitioners estimated their respective tax liabil-
ities to be zero. As filed, petitioners' 1989 and 1990 returns
showed tax liabilities of $66,958 and $70,742, respectively,
after taking account of the losses at issue. Those returns
reported that petitioners received salaries during 1989 and 1990
of $315,662 and $359,962, respectively. Even assuming arguendo
that petitioners were entitled for each year at issue to a deduc-
tion for the loss in question here, petitioners have failed to
establish that they could have reasonably believed that the
deduction for each such year for such loss, together with other
expenses for which they were entitled to deductions, were of such
a magnitude to cause their taxable income for each of those years
to be reduced to zero. It is also significant that for the years
1987 and 1988, the two years preceding the taxable years at
issue, petitioners' Federal income tax returns reflected positive
tax liabilities in the amounts of $16,405 and $62,341, respec-
tively.
Petitioners argue that the respective estimates of their
Federal income tax liabilities for 1989 and 1990 that were shown
in their respective applications for automatic extension for
those years were reasonable because they relied on the advice of
their accountant for the preparation of those applications.
Petitioners' failure to estimate properly their taxes cannot be
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