- 35 - available at the time he or she makes the request for an extension. Id. at 908. As a prerequisite for this treatment, however, the taxpayer must make a bona fide and reasonable attempt to locate, gather, and consult information which will enable him or her to make a proper estimate of his or her tax liability. See id. Petitioners’ taxes were estimated at $3,128 and $8,000 for 1989 and 1991, respectively. These amounts were estimated by petitioners’ accountants, and these were the amounts that the accountants believed to be due for 1989 and 1991. It is the taxpayer’s obligation to supply his or her accountant with complete and accurate records from which to make a reasonable estimate of tax liability. See Estate of Duttenhofer v. Commissioner, 49 T.C. 200, 205 (1967), affd. per curiam 410 F.2d 302 (6th Cir. 1969). Petitioners did not provide all of the necessary information to their accountants in order for them to determine a reasonable estimate of petitioners’ tax liability. In the previous section of this opinion, we held that petitioners were negligent in claiming the bad debt deduction and that they did not reasonably rely on the advice of their accountants because they withheld important information. It follows that petitioners did not make a bona fide and reasonable estimate of the tax liabilities by relying on their accountants. Thus, we conclude that petitionersPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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