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excused merely because they may have relied on the advice of a
tax professional. Berlin v. Commissioner, 59 F.2d 996, 997 (2d
Cir. 1932); see United States v. Boyle, 469 U.S. 241, 249-250
(1985). Petitioners failed to call their accountant as a witness
to explain what information petitioners may have provided or what
advice he may have given them regarding the preparation of the
application for automatic extension for each of the years at
issue. Accordingly, on the instant record, petitioners have
failed to establish that any reliance by them on the advice of
their accountant was reasonable or in good faith.
Petitioners further argue that petitioner is not a tax
specialist and that he was not aware that their applications for
automatic extension for 1989 and 1990 could be invalidated due to
improper estimates of their respective tax liabilities for those
years. Petitioners' argument is baseless. It is particularly
significant that each of the applications for automatic extension
for the years at issue carried a clear warning on its face that
an unreasonable estimate of the taxpayer's tax liability would
cause the extension to be declared "null and void." Petitioners
signed their application for automatic extension for 1989.
Accordingly, at the time they signed that application, petition-
ers knew that an unreasonable estimate in that application of
their tax liability for 1989 would cause the extension to be
declared "null and void." Although petitioners did not sign
their application for automatic extension for 1990, having signed
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