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measuring, weighing or the like. A rough or
approximate calculation only." Black's Law
Dictionary, 494 (5th ed. 1979).
To require exactitude in the estimation
called for under section 1.6081-4(a)(4), Income
Tax Regs., would be unreasonable. The taxpayer
would have no need for an extension of time
within which to file his return if he could
determine his true tax liability at the time
he submits the Form 4868. The mere fact that
petitioners underestimated their 1981 and 1982
tax liabilities, standing alone, does not cause
their applications to be invalid and the auto-
matic extensions to be void. See Hudspeth v.
Commissioner, T.C. Memo. 1985-628.
Id. at 906-907; see also Arnaiz v. Commissioner, T.C. Memo.
1992-729. ("The mere fact that petitioners in fact
underestimated their 1985 tax finally shown to be due does
not mean that they did not properly estimate their tax; the
standard is whether they made a 'bona fide and reasonable
attempt' to secure information * * * necessary to make a
'bona fide' and reasonable estimate' of their tax
liabilities. Crocker v. Commissioner, supra at 907-908.")
Respondent's position that petitioners' allegations
"are not supported by any evidence" disregards the evidence
advanced by petitioners, consisting of Mr. Harrison's
testimony, the testimony of his bookkeeper, Ms. Cates, and
the testimony of the certified public accountants,
Mr. Whittington and Ms. Ruble, whom petitioners retained
to prepare and submit their income tax returns. We found
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