51- - available to him at the time he makes his request for extension, and that a taxpayer must make a bona fide and reasonable attempt to locate, gather, and consult information which will enable him to make a proper estimate of his tax liability. An extension of time to file a return is invalid when the taxpayer fails to make a proper estimation of his tax liability, even if the taxpayer receives no notice of the termination of the extension request. Crocker v. Commissioner, supra at 910-912. In the instant case petitioners' estimate of their tax liability for each year, based on the information available to them at the time of their extension request, was not reasonable. Petitioners concluded that they owed zero tax in addition to the estimated tax payments they had already made for the years 1990 and 1991 based, among other things, on their contentions that they incurred deductible casualty losses in excess of insurance reimbursements, and that they were entitled to deductions for the full amounts of self-employment taxes paid by them in 1990 and 1991. However, we have found that these positions are without merit. As a matter of law, petitioners are entitled to a deduction for only one-half of the self-employment tax paid by them. Sec. 164(f). And they failed to produce evidence showing that they were entitled to casualty loss deductions for 1990 and 1991 in amounts in excess of their insurance reimbursements. Since petitioners failed to "properly estimate" their tax liabilities, the Forms 4868 on which they requested extensions ofPage: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 Next
Last modified: May 25, 2011