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return is not filed, 5 percent of the amount of tax required to
be shown on the return, not to exceed 25 percent in the
aggregate.
In order for a taxpayer to qualify for an extension of time
to file a Federal income tax return, the regulations under
section 6081(a) provide that the taxpayer must show on an
application for extension of time, among other things, the full
amount properly estimated as tax for the year, and the
application must be accompanied by a full remittance of the
amount properly estimated as tax. Crocker v. Commissioner, 92
T.C. 899, 905 (1989); Garrett v. Commissioner, T.C. Memo. 1994-
70; sec. 1.6081-4(a)(4), Income Tax Regs.
A taxpayer will be treated as having "properly estimated"
the tax liability when a bona fide and reasonable estimate is
made on the extension application of the correct tax liability
based on information available to the taxpayer at the time the
application for extension is filed. Crocker v. Commissioner,
supra at 908; Magowan v. Commissioner, T.C. Memo. 1994-152;
Garrett v. Commissioner, supra.
For 1988, the addition to tax for negligence is equal to 5
percent of the underpayment of tax. Sec. 6653(a)(1). Negligence
is the failure to make a reasonable attempt to comply with the
provisions of the Internal Revenue Code. Sec. 6653(a)(3).
Negligence is further defined as a lack of due care or failure to
do what a reasonable and ordinarily prudent person would do under
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