United States v. Boyle, Executor of the Estate of Boyle (469 U.S. 241)
U.S. Supreme Court · decided January 9, 1985 · Supreme Court Database (Spaeth)
- Citation
- 469 U.S. 241 · 105 S. Ct. 687
- Decided
- January 9, 1985
- Term
- October Term 1984
- Vote
- 9–0
- Majority author
- Justice Burger
- Issue area
- Federal Taxation
- Disposition
- Reversed
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Chief Justice Burger delivered the opinion of the Court. We granted certiorari to resolve a conflict among the Circuits on whether a taxpayer’s reliance on an attorney to prepare and file a tax return constitutes “reasonable cause” under § 6651(a)(1) of the Internal Revenue Code, so as to defeat a statutory penalty incurred because of a late filing. f — ( A Respondent, Robert W. Boyle, was appointed executor of the will of his mother, Myra Boyle, who died on September 14, 1978; respondent retained Ronald Keyser to serve as attorney for the estate. Keyser informed respondent that the estate must file a federal estate tax return, but he did not mention the deadline for filing this return. Under 26 U. S. C. § 6075(a), the return was due within nine months of the decedent’s death, i. e., not later than June 14, 1979. Although a businessman, respondent was not experienced in the field of federal estate taxation, other than having been executor of his father’s will 20 years earlier. It is undisputed that he relied on Keyser for instruction and guidance. He cooperated fully with his attorney and provided Keyser with all relevant information and records. Respondent and his wife contacted Keyser a number of times during the spring and summer of 1979 to inquire about the progress of the proceedings and the preparation of the tax return; they were assured that they would be notified…
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