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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
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