The U.S. Court of Appeals for the Eleventh Circuit affirmed a ruling against a man who claimed that because his CPA failed to file his tax returns for three consecutive years, he should not be hit with nearly $80,000 in late penalties due to having a “reasonable cause” for delay.

U.S. Supreme Court case law United States v. Boyle (1985) established the bright-line rule that “reliance on an agent” cannot amount to “reasonable cause” for failure to file a tax return on time. However, no circuit court has yet applied precedent in Boyle to e-filed tax returns.