Issue: Whether a taxpayer demonstrates “reasonable cause”
under 26 U.S.C. § 6651(a)(1) or “ordinary business
care and prudence” under 26 C.F.R. § 301.6651-1(c)(1)
when, in reliance on the advice of the taxpayer’s
accountant or attorney, the taxpayer files a tax return
after the actual due date but within the time the
accountant or attorney erroneously advised the taxpayer
On Monday at 9:30 a.m. we expect orders from the October 17 Conference. We do not expect any decisions on the merits but will report promptly on any orders. The Court's next Conference is scheduled for October 31. The November sitting begins November 3.