Legal Opinion
United States v. Boyle
Supreme Court of the United States
Decided January 9, 1985No. 83-1266PublishedCited by 1,251 opinions
1Opinion of the CourtChief Justice Burger
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…
2Cases cited38 opinions
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- Reed v. RossSupreme Court of the United States · 1984
- Kosak v. United StatesSupreme Court of the United States · 1984
- Bell v. New JerseySupreme Court of the United States · 1983
- Commissioner v. Lane-Wells Co.Supreme Court of the United States · 1944
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3Cited by1,251 opinions
- Pioneer Investment Services Co. v. Brunswick Associates Ltd. PartnershipSupreme Court of the United States · 1993
- K Mart Corp. v. Cartier, Inc.Supreme Court of the United States · 1988
- United States v. LockeSupreme Court of the United States · 1985
- Neonatology Assocs., P.A. v. Comm'rUnited States Tax Court · 2000
- Mark A. Ball v. City of Chicago and Alfred S. Schultz, Individually and as Agent of the City of ChicagoCourt of Appeals for the Seventh Circuit · 1993
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