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Petitioners conceded the issue of liability under section
6654(a) because they did not raise the issue in their petition.
See Rule 331(b)(4); Goza v. Commissioner, 114 T.C. at 183.
Even if petitioners had properly raised this issue in their
petition, we would hold it would not be inequitable or
unconscionable to impose the estimated tax addition on them.
Petitioners did not provide any reason for their failure to pay
estimated taxes. Rather than paying estimated taxes, petitioners
used $989,158 of petitioner’s law practice net profit to pay for
construction of their house in Escambia County. Petitioners
invested another portion of the law practice net profit in
timberland, a highly illiquid investment. Having earned a net
profit from petitioner’s law practice that was more than four
times the amount of the tax liability shown on their return,
petitioners had more than enough money to pay estimated taxes and
still have funds left over for investments and personal outlays.
Moreover, petitioners did not establish any causal link between
the natural disasters and failure to pay estimated tax, such as
damage or loss of their business records that adversely affected
their ability to estimate their tax liability.
b. Failure To Pay Tax With the Request for
Automatic 4-Month Extension
Petitioners did not pay any tax, either when they filed
their Form 4868 on April 15, 1998, or when they requested a
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