If all this were true, why are we required to file under "early filer" status? That is, within 40 days of quarter's end as opposed to the "normal" 45? My understanding is that this burden was placed as a "slap on the wrist" for reporting late (in the extended timeframe) twice.

I suspect that your quote from the regs re: what's an extension is a mixing of context. Think of it like this - if an extension (in the last-quoted context) didn't benefit you in meeting the basic filing requirement, why would you bother filing for an extension? It would serve no purpose.

Having spent a good part of my career interpreting Gov't regs, I KNOW that great care must be taken as to mixing contexts/intent. It requires you think it through a little farther - as to context and intent, and what just makes any sense in the overall scheme.

Again, I suggest the key words (from the earlier quote) are "due date".

SGE