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remitted with the extension request. Sec. 1.6081-4, Income Tax
Regs. Taxpayers "properly estimate" the tax liability when a
bona fide and reasonable estimate of tax liability is made based
on information available at the time of the request for the
extension. Crocker v. Commissioner, 92 T.C. 899, 908 (1989).
Reliance on invalid extensions of time to file tax returns will
not generally constitute reasonable cause for taxpayers' failure
to timely file tax returns. Id. at 913.
Because petitioner failed to properly estimate his Federal
income tax due for 1991, petitioner's request for extension of
time to file a 1991 Federal income tax return was invalid.
Because petitioner's extension was invalid, petitioner's 1991
Federal income tax return was untimely filed, and petitioner has
not shown reasonable cause for his failure to properly estimate
his 1991 Federal income tax and therefore to timely file his 1991
Federal income tax return. We sustain respondent's imposition of
the addition to tax for the late filing of petitioner's 1991
Federal income tax return.
For 1991 and 1992, respondent imposed accuracy-related
penalties equal to 20 percent of the portion of petitioner’s
underpayment in tax attributable to negligence (namely, with
respect to 1991, the disallowed $5,433 investment interest
expense and petitioner’s failure to reflect on the return his
liability for the AMT; with respect to 1992, the disallowed
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