- 15 -
1990. Mr. McVeigh completed and filed on petitioner's behalf
Forms 4868 (Application for Automatic Extension of Time to File
U.S. Individual Income Tax Return (application for automatic
extension)) for those years that were dated April 11, 1990, and
April 5, 1991, respectively, signed by petitioner, and requested
a four-month extension of time until August 15, 1990, and August
15, 1991, respectively, within which to file his returns for
those years. Line 1 of each of those applications required
petitioner to make a reasonable estimate, based on the informa-
tion available, of his tax liability for the year for which he
was seeking an extension. In arriving at the respective esti-
mated tax liabilities for 1989 and 1990 that Mr. McVeigh showed
on line 1 of petitioner's applications for automatic extension
for those years, Mr. McVeigh believed it reasonable, and so
advised petitioner, that, given petitioner's situation, those
estimates be based on the tax liability shown in petitioner's
return for the year immediately preceding the year for which each
such application was being filed, provided that petitioner paid
each of those estimated tax liabilities by the time he filed each
such application. Since the tax liabilities shown in peti-
tioner's 1988 and 1989 returns were $9,041 and $9,043, respec-
tively, Mr. McVeigh entered on line 1 of petitioner's applica-
tions for automatic extension for 1989 and 1990 estimated tax
liabilities of $9,100 and $9,043, respectively. Those respective
applications also indicated that for 1989 estimated tax payments
Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 NextLast modified: May 25, 2011