James G. and Linda C. Jaroff - Page 12

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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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