William O. Harrison - Page 26

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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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