Penalties: Reconsidering the 'Reliance on Professional' Defense to Delinquency Penalties in the Age of E-Filing
4 Pages Posted: 23 Aug 2013
Date Written: February 2012
Following the Supreme Court’s decision in Boyle v. United States, courts traditionally have held that a taxpayer cannot delegate the responsibility to file a tax return to another person and, therefore, cannot avoid a late filing penalty if the other person fails to file on time. However, the IRS now encourages taxpayers to e-file their tax return through e-filing professionals. Under these circumstances, the IRS and courts must re-evaluate whether and when a taxpayer should be penalized if a professional fails to e-file a return on time.
Keywords: penalties, delinquency, late filing, e-filing, Boyle
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