## Facts

- Myra W. Boyle died in 1978; her son, Robert W. Boyle, served as executor of her estate.
- Federal law required the estate tax return to be filed within nine months of death.
- The executor hired an attorney to prepare and file the return, provided all necessary records, and periodically checked on progress.
- The attorney filed the return about three months late due to a clerical calendaring error.
- The IRS assessed a late-filing penalty under 26 U.S.C. § 6651(a)(1); the executor paid and sued for a refund, claiming reliance on counsel was “reasonable cause.”
- The district court and the Seventh Circuit ruled for the executor; the Supreme Court granted review to resolve a circuit conflict.

## Issues

1. Whether a taxpayer’s reliance on an attorney (or other agent) to file a timely estate tax return constitutes “reasonable cause” that excuses the late-filing penalty under 26 U.S.C. § 6651(a)(1).

## Decision

- The Supreme Court reversed unanimously.
- Reliance on an agent to meet a known filing deadline is not “reasonable cause” under § 6651(a)(1) and does not excuse a late filing.
- The Court distinguished reliance on professional advice about substantive tax matters from reliance on an agent for the ministerial act of timely filing.
- A separate concurrence agreed with the result but cautioned that “reasonable cause” should remain capable of covering truly exceptional situations.

## Legal Principles

- Section 6651(a)(1) imposes a penalty for late filing unless the taxpayer shows the failure was due to “reasonable cause” and not “willful neglect.”
- Under the Treasury regulation, “reasonable cause” requires that the taxpayer exercised “ordinary business care and prudence” yet was unable to file timely.
- The duty to ensure a return is filed by a clear statutory deadline is personal and nondelegable; an agent’s clerical error is attributable to the taxpayer for this purpose.
- Reliance on expert advice may support “reasonable cause” when the question involves substantive tax judgment (e.g., whether a return is required), but not when the task is simply meeting an ascertainable deadline.

## Conclusion

The Court held that an executor’s reliance on an attorney to file an estate tax return by a known due date does not constitute “reasonable cause” under § 6651(a)(1); the late-filing penalty applies despite the attorney’s clerical mistake.


United States v. Boyle, 469 U.S. 241 (1985)