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to file a timely return. See Crocker v. Commissioner, 92 T.C.
899, 913 (1989); Estate of Vriniotis v. Commissioner, 79 T.C.
298, 310 (1982); sec. 301.6651-1(c)(1), Proced. & Admin. Regs.
Willful neglect is viewed as a conscious, intentional failure or
reckless indifference to the obligation to file. See United
States v. Boyle, 469 U.S. 241, 245-246 (1985); Estate of Newton
v. Commissioner, T.C. Memo. 1990-208. Whether the taxpayer has
sufficiently shown reasonable cause and no willful neglect is a
question of fact to be decided on the entire record. See Estate
of Duttenhofer v. Commissioner, 49 T.C. 200, 204 (1967), affd.
410 F.2d 302 (6th Cir. 1969).
A taxpayer may establish reasonable cause for failing to
file a timely return by proving that he reasonably relied on the
advice of an accountant or attorney and later found that such
advice was erroneous or mistaken. See United States v. Boyle,
supra at 250; Estate of Paxton v. Commissioner, 86 T.C. 785, 820
(1986); CTUW Georgia Ketteman Hollingsworth Trust v.
Commissioner, 86 T.C. 91, 108-109 (1986). In United States v.
Boyle, supra at 251, the Supreme Court explained that a
taxpayer’s reliance on the advice of an attorney concerning a
matter of law, such as whether a return must be filed,
constitutes reasonable cause because “Most taxpayers are not
competent to discern error in the substantive advice of an
accountant or attorney.” However, the Supreme Court noted that
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