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further extension on August 14, 1998. The due date for payment
of petitioners’ 1997 Federal income tax was April 15, 1998, the
original due date for filing their 1997 return. See sec.
6151(a). For failure to pay taxes shown on a return on or before
the due date for payment (determined with regard to any extension
of time for payment), there shall be added 0.5 percent of the
amount of such tax if the failure is for not more than 1 month,
with an additional 0.5 percent for each additional month or
fraction thereof during which such failure continues, not
exceeding 25 percent in the aggregate. Sec. 6651(a)(2).
In their April 15, 1998, letter, petitioners characterize
their filing of Form 4868 as an extension of time to file and “to
pay the tax due”. The granting by the IRS of an automatic
extension of time to file a return does not operate to extend the
time for payment of any tax shown due on the return. See sec.
1.6081-4(b), Income Tax Regs.
Petitioners did not properly file a separate request for an
extension of time to pay their taxes, which must be made on Form
1127, Application for Extension of Time for Payment of Tax. Nor
did they pay their tax liability when they filed their Form 4868.
As a result, petitioners’ liability for the section 6651(a)(2)
addition to tax began to accrue on April 16, 1998.
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