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
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