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Golemb's signature did not appear on any of the copies of pe-
titioner's returns for the years at issue, although copies of his
signature as return preparer appeared on each of those copies.
No date appeared next to the copies of Mr. Golemb's signature on
the copies of petitioner's 1985 and 1986 returns. Copies of the
dates April 27, 1988, October 12, 1989, April 4, 1990, and April
6, 1991, appeared next to copies of Mr. Golemb's signature on the
copies of petitioner's returns for 1987 through 1990, respec-
tively.
Because, inter alia, petitioner, through Mr. Golemb, main-
tained at the May 21, 1992 meeting that her returns for the years
at issue had been filed, the copies of those returns that Mr.
Golemb presented to the revenue agent on May 21, 1992, were not
treated as filed returns but instead were treated as information
copies only.
The Service, on a date that is not clear from the record,
temporarily processed as filed the copies of petitioner's returns
for the years at issue that Mr. Golemb had presented to the
revenue agent on May 21, 1992. However, around August 13, 1996,
the Service corrected that action on its records and reflected on
those records an entry for "substitute for return" for each year
at issue, which is an administrative entry used in cases where a
taxpayer has not filed a return.
Subsequent to the Service's civil audit of petitioner for
the years at issue, the Service, through its criminal investiga-
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