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percent of his vested interest in the partnership's salary
reduction plan, which should have indicated to him that the
distribution was not limited to the proceeds from the check he
received and negotiated.
Petitioner failed to make a bona fide and reasonable estimate
of his tax liability when he filed Form 4868. See Crocker v.
Commissioner, supra at 908. He underestimated his tax liability by
two-thirds. Cf. Boatman v. Commissioner, T.C. Memo. 1995-356. His
failure to obtain the necessary information to estimate properly
his tax liability, as well as his failure to properly investigate
the law regarding his tax issues, does not excuse the error in
petitioner's estimate. Arnaiz v. Commissioner, supra. Petitioner's
mistaken belief that he was entitled to a loss deduction for the
value of accounts receivable and work in progress "left on the
table" when he departed Heidelberg & Woodliff does not constitute
reasonable cause for failure to make a proper estimate. See Mayhew
v. Commissioner, T.C. Memo. 1994-310. Thus, we sustain
respondent's voiding of the tax filing extensions obtained by
petitioner.
Because petitioner's reliance on the filing extensions
constituted his sole defense to the section 6651 (a)(1) addition to
tax, petitioner has not shown that his failure to timely file his
1991 tax return was due to reasonable cause and not willful
neglect. See Crocker v. Commissioner, supra at 913. Accordingly,
we hold that petitioner is liable for the section 6651(a)(1) 25-
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