We have an IRA customer living abroad. He wants to make his 2003 contribution today because that is when he files his 1040. However, in looking at the regulations it appears that June 15 is an automatic extension granted by the Treasury for filing of his return, not the return's due date, and thus he would have to make IRA contributions by April 15 for it to be treated as made in the prior year. Am I correct in this analysis? Has anyone else had to deal with this issue?

Tax tip 2004-62 "You can contribute to either a traditional or Roth IRA until the April 15 due date of your tax return, without extensions"

http://www.irs.gov/newsroom/article/0,,id=108515,00.html

Same wording on IRS Pub 590 p.11

Extensions for filing do not create extensions for contributing.