Jane B. Oliver and Robert P. Oliver - Page 51

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          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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