For many years, the Boyle rule established that the failure of a third-party accountant to file a tax return by its due date does not establish a taxpayer’s “reasonable cause” for the forgiveness of late-file penalties. But is the Boyle rule consistent with the realities of e-filing? For now, yes. In a 2020 Tax Court case, Padda, the court rejected a taxpayer’s claim that his accountant’s failure to electronically submit his tax returns on time should relieve him of late-file penalties. In that case, the taxpayer’s accountant electronically filed the taxpayer’s tax returns just before midnight. The accountant mistakenly transmitted two electronic versions and the IRS rejected both as duplicates submissions, causing the tax return to be late. There was no empathy at the Tax Court. Following precedent it found that the ultimate responsibility for filing on time falls in the laps of taxpayers (solely). The reasoning is because it requires no special training or effort to ascertain a deadline date and make sure that deadline is met – that is the essence of the Boyle rule. You cannot provide your tax return to a preparer and then wipe your hands clean of it. Get electronic verification that your tax return was filed and “accepted”.