- 29 - "are not supported by any evidence." To find otherwise, according to respondent, the Court would have to disregard "petitioners' past conduct in filing extensions and failing to make proper estimated tax payments" and the Court would have to "accept the unsupported testimony of petitioners and their representatives." Finally, respondent argues that petitioners cannot avoid the delinquency addition by claiming reasonable reliance on their accountants. According to respondent, petitioners have not shown "'that the advisor had sufficient knowledge of the taxpayer's relevant financial circumstances to make an informed decision.'" (quoting Stovall v. Commissioner, T.C. Memo. 1983-450, affd. 762 F.2d 891 (11th Cir. 1985)). Respondent's position in this case places great emphasis on "the past history of petitioners' failure to make proper estimates of Federal tax liability". However troubling we find that history to be, we are mindful of our opinion in Crocker v. Commissioner, 92 T.C. 899, 906 (1989), which states that "a mere comparison of estimated tax liabilities with true tax liabilities will not reveal whether petitioners' estimates were 'proper.'" In that case, we continued with the following: An estimate is no more than that. It is, "A valuing or rating by the mind, without actuallyPage: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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