that; following plaintiffs’ February meeting with Rodgers, plaintiffs were under the impression that Rodgers , .would be handling the estate tax return. See L. West D,ep. 27:14-17; P. West Dep. 33:11-18; J. West Dep. 9:17-22, 10:1-2. Rodgers, however, was not of the same mind;. he believed that Renner, the accountant hired to do June West’s 2009 taxes, was handling the estate tax return. See Rodgers Dep. 15:1-3; 17:7-11,20-22; 18:1-3. Thus; until November 2010, there was apparently a misunderstanding 1997) ("[M]isrepresentations [by counsel about an extension request] do not relieve the taxpayer of his duty to ensure that his tax return was filed on time” because filing a timely return is a "nondelegable duty.”); Estate of Kerber v. United States, 717 F.2d 454, 455-56 (8th Cir,1983) (<HOLDING>) with, e.g., Estate of Thouron v. United
holding that attorneys reliance on district court rules of procedure in filing an appeal constitutes inexcusable neglect recognizing that suppression is not warranted if officers had an erroneous but reasonable belief of authority to consent holding that reliance on an attorneys erroneous belief as to the date of an estate tax filing deadline is insufficient to constitute reasonable cause holding that an anticipated tax refund was property of the bankruptcy estate as of the date the bankruptcy case was filed holding that reasonable reliance is not an element of the defense