United States v. Boyle
United States Supreme Court
469 U.S. 241 (1985)
- Written by Daniel Clark, JD
Facts
Robert Boyle (plaintiff) was the executor of his late mother’s will. Boyle hired an attorney to act on his mother’s estate’s behalf. Boyle dutifully followed the attorney’s advice in administering the estate. Approximately one year after his mother’s death, Boyle learned from the attorney that the Internal Revenue Code required estate tax returns to be filed within nine months of the decedent’s passing and that the estate’s tax return was overdue. Boyle shortly thereafter filed an estate tax return. The Internal Revenue Service accepted the return and assessed a late-filing penalty against the estate. Boyle paid the penalty and then sued the United States (defendant) for a refund of it. The district court ruled in favor of Boyle, finding that Boyle’s reliance on his attorney was reasonable cause to exempt Boyle from the penalty. The court of appeals affirmed, and the United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Burger, C.J.)
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