Ferydoun Ahadpour, a.k.a, F. Ahadpour, And Doris Ahadpour - Page 35




                                       - 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 petitioners           







Page:  Previous  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  34  35  36  Next

Last modified: May 25, 2011