- 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 return
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