CPA’s Serious Illness Did Not Excuse Failure to File Timely

A District Court decision held Serious Illness did not excuse Failure to File Tax Return on Time. J. Frank Best, Tax Controversy CPA/U. S. Tax Court Litigator with locations in Raleigh and Wilmington, NC  & North Myrtle Beach and Myrtle Beach, SC works to stay current on all IRS decisions concerning tax litigation to ensure we are fully informed and prepared for clients.

CPA’s Serious Illness Did Not Excuse Couple’s Failure to File Tax Return on Time

A district court held that a couple who hired a CPA to prepare their tax return did not have reasonable cause for failing to timely file their return as a result of the serious illness and hospitalization of the CPA. The court found that, under U.S v. Boyle, 469 U.S. 243 (1985), reliance on an agent does not constitute reasonable cause, and that the couple did not qualify for the limited exception applicable to a corporate taxpayer that is disabled due to its agent’s intentional conduct that is beyond the corporation’s control or supervision. Willett v. U.S, 2020 PTC 82 (N.D. Cal. 2020).