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was available until July or August 1989, after the Form
4868 was filed in April 1989, and petitioners argue that
the estimates of their income from those activities were
reasonable. Furthermore, petitioners contend that
Mr. Harrison and their accountants made reasonable
attempts to obtain accurate information from both the
Houston firm and the cattle feeding business before the
Form 4868 for 1988 was filed.
In the case of their 1989 tax liability, petitioners
argue that their accountants also made a reasonable
estimate of their tax liability based upon available
information and that they made a reasonable attempt to
obtain accurate information. They argue that Ms. Ruble's
"oversight regarding capitalization of leasehold improve-
ments" which caused the estimate to be understated should
not cause the estimate to be considered improper.
Alternatively, petitioners argue, if the Court finds
that proper estimates were not made for 1988 or 1989,
then the Court should find that the additions to tax under
section 6651(a)(1) determined by respondent are not
applicable because petitioners' failure to timely file was
due to reasonable cause and not due to willful neglect.
Petitioners argue that they relied upon their accountants,
Ms. Cates, Ms. Ruble, and Mr. Whittington "to prepare
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