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for Automatic Extension of Time to File U.S. Individual
Income Tax Return, and file the form with the appropriate
internal revenue officer on or before the due date
prescribed for filing the taxpayer's income tax return.
Sec. 1.6081-4(a)(2) and (3), Income Tax Regs. Section
1.6081-4(a)(4), Income Tax Regs., as in effect during
the years in issue, provided that such application for
extension:
must show the full amount properly estimated as
tax for such taxpayer for such taxable year, and
such application must be accompanied by the full
remittance of the amount properly estimated as
tax which is unpaid as of the date prescribed for
the filing of the return.
A taxpayer will be treated as having "properly
estimated" his tax liability, within the meaning of
section 1.6081-4(a)(4), Income Tax Regs., quoted above,
when he makes a bona fide and reasonable estimate of his
tax liability based on the information available to him
at the time he makes his request for an extension. Crocker
v. Commissioner, supra at 908. As a prerequisite for this
treatment, however, the taxpayer must make a bona fide and
reasonable attempt to locate, gather, and consult informa-
tion which will enable him to make a proper estimate of
his tax liability. Crocker v. Commissioner, supra.
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