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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.
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