- 10 - tion division, conducted a criminal investigation of petitioner for those years. Petitioner admitted to the Service's special agent responsible for that investigation (special agent) that she was aware of her obligation to file returns and that she knew the consequences of not filing returns. Petitioner told the special agent that she filed her 1985 and 1986 returns, that Mr. Golemb filed her 1987, 1988, and 1989 returns for her, and that she filed her 1990 return. Petitioner also advised the special agent that sometime during 1987 Mr. Golemb told her that he had not filed her returns, which prompted her to file her 1985 and 1986 returns in 1987. However, petitioner did not file her 1985 and 1986 returns in 1987. Petitioner also informed the special agent that she and Mr. Golemb had speculated that the Service had not contacted her with respect to her failure to make tax payments because it might have lost her records due to her name change after she divorced Mr. Reynolds. Petitioner gave the special agent incorrect information about payments for certain house roof repairs, which petitioner claimed that she made but which in fact were paid by Mr. Reynolds. On March 6, 1996, a plea agreement in United States v. Christianson (plea agreement) was filed in the U.S. District Court for the Southern District of California, in which peti- tioner pleaded guilty under section 7203 to failing willfully to file her 1990 tax return. Petitioner admitted in the plea agreement that she knew that she was required to file a returnPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011