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As stated in section 1.6081-4(a)(4), Income Tax Regs.,
quoted above, the granting of an automatic extension of
time within which a taxpayer may file an income tax return
does not operate to extend the time for payment of any tax
due on such return. See Crocker v. Commissioner, supra at
905; sec. 1.6081-4(b), Income Tax Regs. A taxpayer who
computes his taxes on a calendar year basis must pay his
taxes by the 15th of April following the close of such
calendar year regardless of whether he has been granted
an extension of time to file his return. Secs. 6151(a);
6072(a).
In this case, petitioners ask the Court to find that
the estimates of their tax liability made by their
accountants on the Forms 4868 filed for 1988 and 1989 were
proper. According to petitioners, they made a "bona fide
and reasonable estimate of their tax liability based upon
the information available to petitioners at the time of the
making of the extension requests." Petitioners also assert
that their accountants made "a bona fide and reasonable
attempt to locate, gather and consult information which
would enable them to make a reasonable estimate."
In the case of their 1988 tax liability, petitioners
note that neither the Schedule K-1 from the Houston firm,
nor the income statement from the cattle feeding business
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