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neglect. This addition to tax is 5 percent of the tax required
to be shown on the return per month of such failure, up to 25
percent. Sec. 6651(a)(1). Respondent has determined that the
corporate petitioner's extensions of time to file for taxable
years ending September 30, 1987 and 1988 were invalid and that
the corporate petitioner is liable under this section.
The corporate petitioner asserts that the extensions for
both years were valid, but offers no proof and no argument other
than that respondent did not prove the extensions to be invalid.
The corporate petitioner has the burden of proof to show the
additions are improper. United States v. Boyle, 469 U.S. 241,
245 (1985); Funk v. Commissioner, 687 F.2d 264, 266 (8th Cir.
1982), affg. T.C. Memo. 1981-506. The Commissioner may void an
extension where the taxpayer's request for extension is invalid
because of a failure to properly estimate tax liability. Crocker
v. Commissioner, 92 T.C. 899, 911 (1989). The corporate
petitioner has not shown it made a bona fide and reasonable
estimate of its tax liability at the time the requests for
extension were made. We hold for respondent on this issue.
Additions to Tax and Penalties for Negligence
Respondent has determined that all of the corporate
petitioner's underpayments for the years at issue were due to
negligence or disregard of rules or regulations and imposed an
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