Carlye A. Christianson - Page 8




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          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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