Charles R. Godwin et al. - Page 18

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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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