- 51 - sioner, supra at 911. One of the requirements set forth in that section is that that application must show a proper estimate of the taxpayer's tax liability for the taxable year for which the taxpayer is seeking an extension. Sec. 1.6081-4(a)(4), Income Tax Regs. In addition, an application for automatic extension must be accompanied by a full remittance of the unpaid portion of that estimated tax liability. Id. A taxpayer's estimate of his or her tax liability is proper if, considering the information available at the time the application for automatic extension is filed, it is a bona fide and reasonable estimate. Crocker v. Commissioner, supra at 908. A taxpayer is obligated to make a reasonable attempt to gather information necessary to the proper estimation of his or her tax liability. Id. If in the tax- payer's application for automatic extension the taxpayer "esti- mated his tax liability to be zero, even though he had, at the time he submitted the request, ample evidence discrediting the estimate," that application would be invalid. Id. For each of the years at issue, petitioners were required to file their return by April 15 following the close of each such year. Sec. 6072(a). Petitioners filed applications for auto- matic extension for the years 1989 and 1990 dated April 13, 1990, and April 12, 1991, respectively. Since petitioners filed an application for automatic extension for each of the years at issue, the determination of whether their returns for those years were timely filed will depend on whether those applications arePage: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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