In the United States v. Boyle case of 1984, the Supreme Court ruled that taxpayers are responsible for filing their tax returns on time and cannot blame their accountant or attorney if they fail to do so. The case involved an executor who was late in filing a federal estate tax return because his lawyer had given him incorrect information about the due date. As a result, he incurred significant penalties from the Internal Revenue Service (IRS). He argued that he should not be held liable for these penalties since it was his lawyer's mistake, not his own. However, the court disagreed and held that taxpayers have a duty to ensure their taxes are filed correctly and on time regardless of any advice they may receive from professionals.

In the dissenting opinion for United States v. Boyle, Justice Blackmun argued that a taxpayer should not be penalized for late filing when relying on an agent to file taxes in a timely manner. He believed that this reliance was reasonable and consistent with common law principles of agency, which hold agents responsible for their actions while acting on behalf of principals. The majority's decision to impose penalties regardless of whether taxpayers reasonably relied on professionals contradicted these principles and unfairly punished taxpayers who acted in good faith but were let down by their agents. Furthermore, he criticized the court's failure to distinguish between different types of negligence - i.e., simple mistakes versus gross negligence or willful misconduct - arguing it would lead to unjust outcomes where minor errors resulted in disproportionate penalties.