- 35 -                                         
             returns through oversight.  If it were, petitioners could                
             not escape the application of section 6651(a)(1) by                      
             claiming reliance on their accountants.  See United States               
             v. Boyle, supra at 252; McGee v. Commissioner, 979 F.2d 66,              
             70-71 (5th Cir. 1992), affg. per curiam T.C. Memo. 1991-                 
             510; Denenburg v. United States, 920 F.2d 301 (5th Cir.                  
             1991).  For example, in United States v. Boyle, supra, the               
             executor of an estate, argued that reliance on an attorney               
             was "reasonable cause" for failure to meet the filing                    
             deadline for an estate tax return.  The Court stated that                
             it was not "reasonable" for the executor to "assume" that                
             the attorney would comply with the statute.  United States               
             v. Boyle, supra at 250.  The Supreme Court held:  "The                   
             failure to make a timely filing of a tax return is not                   
             excused by the taxpayer's reliance on an agent, and such                 
             reliance is not 'reasonable cause' for a late filing under               
             �6651(a)(1)."  United States v. Boyle, supra at 252.  In                 
             its opinion, the Supreme Court made it clear that the case               
             before it was not one in which "a taxpayer has relied on                 
             the erroneous advice of counsel concerning a question of                 
             law", such as the advice of an accountant or attorney that               
             it was unnecessary to file a return.  Id. at 250.                        
                  In this case, petitioners and their accountants did                 
             more than the executor and his lawyer in United States                   
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