Srichai and Pusadee Rungrangsi - Page 18

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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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