Peter Knappe asked his accountant to apply for an extension of the deadline to file the estate-tax return from the Internal Revenue Service (IRS). The accountant told Knappe that the deadline had been extended one year, when in fact it had been extended only six months. Acting on the bad advice, Knappe filed the tax return several months late, and the IRS assessed significant penalties against the estate. Knappe requested anabatement of the penalty. The Internal Revenue Code excuses late-filing executors from penalties if the failure to file was "due to reasonable cause and not due to willful neglect." Knappe contends that his reliance on his accountant's erroneous advice was reasonable cause for the late filing. Should the taxpayer be excused from the late penalty? Explain.