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petitioner's return is deemed to have been filed on December 17,
1993, the date it was received by respondent, the return was
filed late for a period of 4 months and a portion of a fifth
month. Accordingly, we sustain respondent's determination that
petitioner is liable for the maximum addition to tax under
section 6651(a).
To reflect the foregoing,
Decision will be entered
under Rule 155.
6(...continued)
extension are invalid where the taxpayer failed to properly
estimate the amount of tax owed for the taxable year. Crocker v.
Commissioner, 92 T.C. 899, 910 (1989). Since the validity of the
application for automatic extension does not affect the
calculation of the addition to tax in this case, we need not, and
do not, consider this issue.
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