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those estimates be based on the tax liability shown in peti-
tioner's return for the year immediately preceding the year for
which each such application was being filed, provided that
petitioner paid each of those estimated tax liabilities by the
time he filed each such application. Since the tax liabilities
shown in petitioner's 1988 and 1989 returns were $9,041 and
$9,043, respectively, Mr. McVeigh entered on line 1 of peti-
tioner's applications for automatic extension for 1989 and 1990
estimated tax liabilities of $9,100 and $9,043, respectively.
Those respective applications also indicated that for 1989
estimated tax payments of $9,100 were made by petitioner and that
for 1990 $4,908 of tax was withheld from petitioner and $4,135 of
tax was paid with his 1990 application for automatic extension.
When an accountant advises a taxpayer on a matter of tax law
in circumstances such as these, it is reasonable for the taxpayer
to rely on that advice. See United States v. Boyle, supra at
251. On the record before us, we find that petitioner's reliance
on Mr. McVeigh's advice with respect to the preparation of his
applications for automatic extension of time for 1989 and 1990
was reasonable and in good faith and constituted reasonable cause
within the meaning of section 6651(a)(1). Accordingly, we reject
respondent's determinations under section 6651(a)(1) for 1989
and, with one exception, for 1990. That exception for 1990
relates to the facts that petitioner's return for that year was
dated October 25, 1991, and was received by the Service on
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