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 of
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