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which he was required to estimate his expected tax liability.
Form 4868 provides that the taxpayer can estimate this amount so
long as that estimate is reasonable.
Petitioner stated on his 1989 Form 4868 that he expected his
total tax liability for 1989 to be $9,404. After including the
income from Mr. Hall, petitioner's total tax liability was
determined to be $54,935. Petitioner's estimate of $18,650 on
his 1990 Form 4868 was much closer to his total tax liability for
1990, which was determined to be $25,101. However, when
petitioner filed his 1990 Federal income tax return, he stated
that his total tax liability for 1990 was only $3,086 and claimed
and received a refund of $15,564. On his 1991 Form 4868,
petitioner stated that he expected his 1991 total tax liability
to be $16,675, when, in fact, it was determined to be $76,583.83.
Therefore, even though Form 4868 specifically provides that it is
appropriate to make an estimate, in at least 2 of the 3 years in
issue, petitioner obviously failed to include any reasonable
amount of income from Mr. Hall in his estimated total tax
liability.
Finally, petitioner asserts that he is not liable for the
fraud penalty because he relied on Mr. Pressley's advice in
filing his original Federal income tax returns for 1989, 1990,
and 1991. Generally, the duty of filing accurate returns cannot
be avoided by placing responsibility on a tax return preparer.
Metra Chem Corp. v. Commissioner, 88 T.C. 654, 662 (1987); Bailey
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