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following the close of the calendar year. Sec. 6072(a). An
individual taxpayer may receive an automatic 4-month extension by
filing a Form 4868 on or before the due date. Sec. 1.6081-
4(a)(2), Income Tax Regs. (applicable to taxable year 1994); sec.
1.6081-4T(a)(2)(i), Temporary Income Tax Regs., 61 Fed. Reg. 261
(Jan. 4, 1996) (applicable to taxable year 1995). If a taxpayer
requires an additional extension of time to file, he or she may
make such a request by filing a Form 2688. Secs. 1.6081-1(a) and
(b)(5), 1.6081-4(a)(5), Income Tax Regs.; sec. 1.6081-4T(a)(5),
Temporary Income Tax Regs., supra.
For the automatic 4-month extension to be effective, the
application on Form 4868 “must show the full amount properly
estimated as tax for the taxable year”. Sec. 1.6081-4(a), Income
Tax Regs.; sec. 1.6081-4T(a)(4), Temporary Income Tax Regs.,
supra. In addition, for taxable year 1994, the taxpayer is
required to remit the estimated tax when filing the Form 4868.
Sec. 1.6081-4(a), Income Tax Regs. To properly estimate his or
her tax liability, a taxpayer must make a bona fide and
reasonable attempt to locate, gather, and consult information
that will enable him or her to make a proper estimate of his or
her tax liability. See Crocker v. Commissioner, 92 T.C. 899,
908-910 (1989).
Petitioners are deemed to have admitted, through items (10)-
(15) of the request, the following: (1) They did not make bona
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