- 54 - their application for automatic extension for 1989, they knew, or should have known, that, as with their application for automatic extension for 1989, an unreasonable estimate in their application for automatic extension for 1990 of their tax liability for that year would cause the extension to be declared "null and void." We also note that although petitioner was not a tax special- ist, he was an attorney and a sophisticated businessman. Given his professional background, petitioner should have been aware of the importance of providing accurate information when applying for an extension of time to file petitioners' 1989 and 1990 returns. Petitioners also argue that they were not able to estimate properly their respective tax liabilities for 1989 and 1990 because they were involved in several ventures and the records reflecting the income and loss from those ventures were lengthy and complicated. Petitioners have failed to show that they made any reasonable attempt to gather the necessary information or to compile the available information to arrive at a reasonable estimate of their respective income tax liabilities for the years at issue. On the instant record, we find that petitioners have not established that they made bona fide and reasonable estimates of their tax liabilities for 1989 and 1990. We further find that their applications for automatic extension for those years were invalid. Accordingly, petitioners were required to file theirPage: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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