Carlye A. Christianson - Page 10




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          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 return              




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