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petitioner’s admission that he knows now, and knew in 1991, that
his returns were due on April 15 following the tax year.
Petitioner’s only apparent theory for avoiding liability
for the late-filing additions is that he relied on his accountant
to make sure his returns were timely filed. However, the Supreme
Court made it clear in United States v. Boyle, 469 U.S. 241, 249-
50 (1985), that a taxpayer cannot avoid late-filing additions to
tax merely by showing that he relied on an agent to file his tax
return. Petitioner also failed to introduce any evidence to show
that the delay was caused by his accountant’s neglect, as opposed
to petitioner’s own neglect.
Therefore, we hold that petitioner is liable for the late-
filing additions to tax as determined by respondent.
Issue 2. Accuracy-Related Penalty Under Section 6662
Section 6662(a) imposes a 20-percent penalty on the
underpayment of tax attributable to, among other things, the
taxpayer’s “negligence”, sec. 6662(b)(1), or “substantial
understatement of income tax”, sec. 6662(b)(2). Negligence is
defined to include the “failure to make a reasonable attempt to
comply” with the tax laws. Sec. 6662(c). A “substantial
understatement” is an understatement for the taxable year
exceeding the greater of 10 percent of the proper tax, or $5,000.
Sec. 6662(d)(1)(A).
Petitioner’s tax return for 1991 showed tax due of $468.
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