- 8 -
tion with the revenue agent, petitioner stated that if her
returns had not been filed, it was the fault of her return
preparer, Mr. Golemb, who was responsible for filing petitioner's
returns for her. Petitioner also told the revenue agent at
another time that if the Service had no record of petitioner's
having filed her returns, the Service must have lost her returns.
On May 21, 1992, the revenue agent met with Mr. Golemb (May
21, 1992 meeting) who was authorized to represent petitioner with
respect to the Service's examination of her. At that meeting,
the revenue agent and Mr. Golemb agreed that petitioner had filed
joint returns under the name Carlye Reynolds with Mr. Reynolds
for 1983 and 1984.
As for petitioner's returns for the years at issue, Mr.
Golemb informed the revenue agent at the May 21, 1992 meeting
that it was petitioner's position that originals of those returns
had been filed with the Service. He told the revenue agent that
he had retained copies of those returns that he could present to
her. Later in the day on May 21, 1992, Mr. Golemb presented the
revenue agent with copies of petitioner's returns for the years
at issue. The copy of petitioner's 1985 return that Mr. Golemb
presented to the revenue agent on May 21, 1992, was not signed or
dated by petitioner. The original signature of petitioner
appeared on each of the copies of petitioner's returns for 1986
through 1990 that Mr. Golemb gave the revenue agent on that day,
but no date appeared next to her signature. The original of Mr.
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