The US Court of Appeals for the Sixth Circuit upheld a district court decision finding Mo Vaughn liable for failure to timely file returns and pay income tax.  Vaughn, a former Major League first baseman, was the American League’s most valuable player in 1995 but received only 1.1% of the vote in his first year of hall-of-fame eligibility in 2009, dropping off the ballot.  From 2004 to 2008, Vaughn entrusted a financial manager and an accountant with the tasks of filing and paying his taxes.  Instead of fulfilling these tasks, they embezzled millions of dollars from his bank accounts and left Vaughn with a significant unpaid tax liability.  The Sixth Circuit held that Vaughn’s statutory duty to make sure his taxes were properly filed and paid was non-delegable and is not excused because of the felonious actions of his financial agents.  The court further held that because the circumstances that led to Vaughn’s late filing and payment were under his control and subject to his oversight, he did not satisfy the “reasonable cause” exception to the penalties in section 6651(a)(1).