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reason to conclude that it is unnecessary to evaluate the
reasonableness of petitioners' estimate for 1988 in terms
of their full tax liability, what Crocker v. Commissioner,
supra at 906, referred to as the taxpayer's "true tax
liability." As a result, petitioners have not established
the reasonableness of the estimate made on petitioners'
behalf on Form 4868 for 1988. Accordingly, we find that
petitioners have not met their burden of disproving
respondent's determination that the Form 4868 for 1988
was void and that petitioners failed to make a timely
return for 1988.
Similarly, petitioners' evidence for 1989 shows that
in computing petitioners' estimated tax liability
Ms. Ruble assumed that all of the amounts classified by
Ms. Cates as office expenses for petitioners' Corpus
Christi law office were fully deductible, whereas that
total included approximately $80,000 of capital
expenditures. According to petitioners: "That
classification difference, capitalized vs. deductible
leasehold improvements, accounted for the difference in
tax liability between the amount estimated and that shown
due on the return." As was true in the case of 1988,
petitioners have limited their case to showing the
reasonableness of their estimated tax liability for 1989,
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