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Petitioners assert that they were entitled to automatic 4-
month extensions for the filing of their returns for each of the
years in issue. In order to obtain an automatic 4-month filing
extension, the taxpayer must satisfy three requirements. The
taxpayer must: (1) Prepare and sign Form 4868, Application For
Automatic Extension of Time to File U.S. Individual Income Tax
Return; (2) file Form 4868 on or before the date on which the tax
return is due; and (3) properly estimate the tax due for such
taxable year and remit the unpaid balance. Condor Intl., Inc. v.
Commissioner, 98 T.C. 203, 224 (1992), affd. in part and revd. in
part on other grounds 78 F.3d 1355 (9th Cir. 1996); see also sec.
1.6081-4, Income Tax Regs.
Petitioners did not offer any copies of Forms 4868 for the
years in issue or other evidence to establish that they satisfied
the requirements for obtaining the automatic extension. Moreover,
they offered no proof as to whether they had reasonable cause for
failing to timely file their returns. Thus, we sustain
respondent's determination as to the addition to tax pursuant to
section 6651(a) for each of the years in issue.
Issue 5. Accuracy-Related Penalties
The final issue for decision is whether petitioners are liable
for the accuracy-related penalty due to negligence or disregard of
rules or regulations pursuant to section 6662 for each of the years
in issue.
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