Wicker Corporation made estimated tax payments of $6,000 in Year 1. On March 12 of Year 2, it filed its Year 1 tax return showing a $20,000 tax liability, and it paid the $14,000 balance at that time. On April 20 of Year 2, it discovers an error and files an amended return for Year 1 showing a reduced tax liability of $8,000. Prepare a memorandum for your tax manager explaining whether Wicker can base its estimated tax payments for Year 2 on the amended $8,000 tax liability for Year 1, or whether it must use the $20,000 tax liability reported on its original Year 1 return. Your manager has suggested that, at a minimum, you consult the following resources:

• IRC Sec. 6655(d)(1)

• Rev. Rul. 86-58, 1986-1 C.B. 365