William O. Harrison - Page 24

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             accountants "properly estimated" petitioners' tax liability              
             on the Forms 4868, Application for Automatic Extension of                
             Time to File U.S. Individual Income Tax Return, that were                
             filed for those years.  See sec. 1.6081-4(a)(4), Income                  
             Tax Regs.  If petitioners' tax liability was not properly                
             estimated, then the extensions of time to file are invalid               
             and petitioners' returns are delinquent.  Crocker v.                     
             Commissioner, 92 T.C. 899, 910 (1989).  In that event,                   
             petitioners are liable for the addition to tax under                     
             section 6651(a)(1), unless they establish that the failure               
             to file their returns by the date prescribed by law is due               
             to reasonable cause and not due to willful neglect.  Id.                 
             at 912-914.                                                              
                  Generally, individuals who compute their Federal                    
             income tax on the basis of the calendar year are required                
             to file their return on or before April 15th following                   
             the close of such year.  Sec. 6072(a).  The Secretary of                 
             the Treasury or his delegate may grant a reasonable                      
             extension of time for filing a return.  Sec. 6081(a).                    
             Regulations promulgated pursuant to that authority                       
             state that individual taxpayers may obtain an automatic                  
             4-month extension of time to file their return.  Sec.                    
             1.6081-4(a)(1), Income Tax Regs.  In order to do so, the                 
             taxpayer must prepare and sign a Form 4868, Application                  






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