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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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