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proper estimates so as to cause the tax returns to be filed
on time" and "[A]ny failure of Petitioners to file tax
returns on time would have been the result of the failure
of their accountants to make a proper estimate."
Respondent contends that the Forms 4868 filed by
petitioners for the years 1988 and 1989 were invalid
because petitioners failed to estimate properly their tax
liability as required by section 1.6081-4(a)(4), Income Tax
Regs. Respondent points out that petitioners' Forms 4868
for 1988 and 1989 estimated their tax liability to be
$1,408 and $2,200, respectively, whereas petitioners paid
$101,093 and $41,915 with their 1988 and 1989 returns,
respectively. Respondent also notes that the parties have
agreed that petitioners' corrected income tax liabilities
for 1988 and 1989 are $176,998 and $116,389, respectively.
Respondent contends that petitioners have a history
of failing to make proper estimates of their Federal tax
liability. According to respondent, "[F]or each of the
years 1986 through 1992, petitioners filed both Form 4868
and Form 2688 extension agreements" and "[F]or each of
these years, petitioners paid 99 percent of their Federal
income tax liability with their filed return in October."
Respondent asserts that petitioners' allegations that
their estimates for the years in issue were reasonable,
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