- 43 - 469 U.S. 241, 246 (1985); sec. 301.6651-1(c)(1), Proced. & Admin. Regs. For 1989 and 1990, petitioner filed applications for auto- matic extension that were dated April 11, 1990, and April 5, 1991, respectively, and that requested a four-month extension of time until August 15, 1990, and August 15, 1991, respectively, within which to file his returns for those years. The parties agree that petitioner also filed a second request (application for additional extension of time) that was dated August 8, 1991, in order to extend the period within which to file his 1990 return to October 15, 1991. Petitioner contends that the addition to tax under section 6651(a)(1) should not be imposed for either 1989 or 1990 because he relied on Mr. McVeigh to prepare the applications for auto- matic extension for those years. Respondent disagrees. We have found as facts that petitioner relied on Mr. McVeigh to prepare requests to extend the time within which to file his returns for 1989 and 1990. Line 1 of each of those requests required petitioner to make a reasonable estimate, based on the information available, of his tax liability for the year for which he was seeking an extension. In arriving at the respective estimated tax liabilities for 1989 and 1990 that Mr. McVeigh showed on line 1 of petitioner's applications for automatic extension for those years, Mr. McVeigh believed it reasonable, and so advised petitioner, that, given petitioner's situation,Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
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