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$2,200, as compared to total tax of $38,702 reported on
their 1989 return. Petitioners have not addressed the
adjustments determined in the notice of deficiency, as
revised by the agreed computation of the 1989 deficiency,
on the basis of which their total tax liability is
$116,389, or $77,687 more than the tax reported on their
return, nor have petitioners shown any reason to conclude
that it is unnecessary to evaluate the reasonableness of
petitioners' estimate for 1989 in terms of their true tax
liability. As a result, petitioners have not established
the reasonableness of the estimate made on petitioners'
behalf on Form 4868 for 1989. Accordingly, we find that
petitioners have not met their burden of disproving
respondent's determination that Form 4968 for 1989 was void
and that petitioners failed to make a timely return for
1989.
This brings us to petitioners' alternative contention
that, even if we find that petitioners failed to file
timely returns, we should, nevertheless, find that the
additions to tax under section 6651(a)(1), as determined by
respondent, are not applicable because petitioners' failure
to timely file was due to reasonable cause and not due to
willful neglect. In this regard, petitioners assert that
they relied upon their accountants to compute their
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