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v. Boyle, supra. In this case, petitioners' accountants
prepared Forms 4868, including the accountants' computation
of petitioners' estimated tax liability, and filed the
forms on petitioners' behalf before the filing deadline.
The filing of each of these forms on which petitioners'
accountants had estimated petitioners' tax liability for
the year constituted the advice of petitioners' accountants
not only as to petitioners' estimated tax liability but
also as to petitioners' filing obligations. This is the
type of substantive advice of an accountant as to which it
is reasonable for a taxpayer to rely. Id. at 251. The
late filing in this case was not due to an oversight or
inattention on the part of petitioners or their
accountants. It was due to the advice of petitioners'
accountants that petitioners' tax liability was properly
estimated on the Forms 4868 filed for 1988 and 1989, and
that they had validly claimed an automatic extension to
file the return for each year. This advice, on which
petitioners relied, constitutes "reasonable cause" for
petitioners' failure to file timely returns. See
Commissioner v. American Association of Engrs. Employment,
Inc., 204 F.2d 19, 21 (7th Cir. 1953), affg. a Memorandum
Opinion of this Court; Burton Swartz Land Corp. v.
Commissioner, 198 F.2d 558, 560 (5th Cir. 1952), affg. in
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