- 36 - did not properly estimate their 1989 and 1991 tax liabilities, the extension requests were not valid, and the 1989 and 1991 returns were not timely filed. Therefore, we hold that petitioners are liable for the additions to tax for delinquency under section 6651(a)(1) for 1989 and 1991.13 To reflect the foregoing, Decision will be entered under Rule 155. 13 The parties also argued whether petitioners’ returns were timely filed, i.e., postmarked on or before the due dates of the returns. Because petitioners’ extension requests were not valid, we need not address this issue.Page: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36
Last modified: May 25, 2011