United States v. Boyle, Executor of the Estate of Boyle

Decided January 9, 1985. Warren Earl Burger delivered the opinion of the Court.

Docket 83-1266 · 469 U.S. 241 (1985) · Cited 1,888 times

Holding

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).

The Court’s statement of the holding, from the opinion’s syllabus. The syllabus is prepared by the Reporter of Decisions and is not part of the opinion of the Court — read the official opinion for authority.

How the Justices voted

Decided 9–0.

“Concurring” means agreeing with the outcome; any split shown is the Court’s judgment, not each Justice’s reasoning. Source: the Supreme Court Database (Spaeth et al.), Washington University.

Precedents cited

Supreme Court decisions this opinion relies on, ordered by how often it cites each. Cases in our collection link through; others are named.

• Chevron U. S. A. Inc. v. Natural Resources Defense Council, Inc. · 467 U.S. 837 (1984)
• Reed v. Ross · 468 U.S. 1 (1984)
• Kosak v. United States · 465 U.S. 848 (1984)
• Bell v. New Jersey · 461 U.S. 773 (1983)
• Commissioner v. Lane-Wells Co. · 321 U.S. 219 (1944)
• Heckler v. Day · 467 U.S. 104 (1984)

Cited by

Later Supreme Court opinions in our collection that cite this case.

• United States v. Locke · 471 U.S. 84 (1985)
• Pioneer Investment Services Co. v. Brunswick Associates Ltd. Partnership · 507 U.S. 380 (1993)
• K Mart Corp. v. Cartier, Inc. · 486 U.S. 281 (1988)

Official text

Read the official opinion (U.S. Reports, govinfo.gov)

Explore from here

Warren Earl Burger’s profile · All Supreme Court opinions · The Supreme Court

Source: Supreme Court of the United States, slip opinions (1985). Citation count from the Free Law Project’s CourtListener bulk data. Data last verified 2026-07-03. Informational only; verify against the primary source before relying. Not a consumer report (FCRA).