Carlye A. Christianson - Page 4




                                        - 4 -                                         
          the 1981-1983 Form 870 was, inter alia, Form 886-A, Explanation             
          of Items, which stated in pertinent part:                                   
                    You failed to timely file your 1981 and 1982                      
               Federal income tax returns.  You arranged to have your                 
               returns prepared only upon contact and request by                      
               personnel of the IRS.  As attorneys, you knew of your                  
               obligation to file tax returns, especially with                        
               adjusted gross income exceeding [$]100,000 annually.                   
                        *     *     *     *     *     *     *                         
                    You are reminded that failure to file timely                      
               federal income tax returns can result in criminal                      
               prosecution and assertion of civil fraud penalties.                    
               Although Mr. Golemb, as the authorized representative of               
          petitioner and Mr. Reynolds, could have signed the 1981-1983 Form           
          870 on their behalf, it was Mr. Golemb's practice not to sign               
          such a form on behalf of his clients.  Instead, Mr. Golemb                  
          required the taxpayer to which such a form pertained to sign it.            
          In light of Mr. Golemb's practice regarding the signing of a Form           
          870, both petitioner and Mr. Reynolds, as the taxpayers to which            
          the 1981-1983 Form 870 pertained, were supposed to have signed              
          that form in order for it to be effective.                                  
               As a result of the Service's audit of petitioner and Mr.               
          Reynolds with respect to 1981 through 1983, petitioner was aware            
          that, at a minimum, no return for 1982 was filed during her                 
          marriage to Mr. Reynolds.  She also had heard rumors that,                  
          because of that audit, Mr. Reynolds could have been imprisoned              
          for failure to file a return.  Petitioner was fully aware of the            
          possible criminal consequences for failing to file a return.                





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