Arnold P. Mordkin and Cindy Mordkin - Page 54

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          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 their              




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