50- -
return was received by respondent on August 19, 1991, and their
1991 return was received by respondent on July 20, 1992.
Respondent takes the position that the applications for
automatic extensions were invalid because petitioners did not
comply with regulations for obtaining such extensions, and,
therefore, the applications for automatic extensions were null
and void. Section 1.6081-4(a)(4), Income Tax Regs., provides
that the application for extension must show the full amount
properly estimated as tax for the taxpayer for the taxable year,
and that the application must be accompanied by
the full remittance of the amount properly estimated as tax which
is unpaid as of the date prescribed for filing the return. An
extension of time to file a return does not extend the time for
payment of tax due on the return. Sec. 1.6081-4(b), Income Tax
Regs.
Petitioners made no payment of tax with their extension
requests for 1990 or 1991, although they made estimated tax
payments of $7,711.20 for 1990 and $10,246.60 for 1991.
Petitioners underestimated their 1990 estimated tax liability by
approximately $25,000 and their 1991 tax liability by
approximately $50,000.
In Crocker v. Commissioner, 92 T.C. 899, 908 (1989), this
Court held that a taxpayer should be treated as having "properly
estimated" his tax liability when he makes a bona fide and
reasonable estimate of his tax liability based on the information
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