Carlye A. Christianson - Page 11




                                       - 11 -                                         
          for 1990 by April 15, 1991, and willfully failed to do so and               
          that she "went so far as to have an income return prepared by a             
          tax return preparation business which calculated a tax due and              
          owing for calendar year 1990 in the amount of approximately                 
          $35,061 and then willfully failed to file the return with the               
          Internal Revenue Service."  Petitioner also admitted in the plea            
          agreement that she "willfully failed to file required returns               
          with the Internal Revenue Service for tax years 1987, 1988 and              
          1989, failing to report an additional tax due and owing in the              
          amount of approximately $39,753."  When petitioner entered into             
          the plea agreement, she had had a full opportunity to discuss all           
          the facts and circumstances of the case with her defense counsel            
          and had a clear understanding of the charges and the consequences           
          of her plea.  She pleaded guilty in the plea agreement because              
          "in truth and in fact defendant [petitioner] is guilty and for no           
          other reason."                                                              
               After the criminal case with respect to petitioner had                 
          concluded, the revenue agent examined petitioner's bank accounts            
          for the years at issue to determine whether there was cash                  
          available to pay the tax that she owed for each of those years.             
          The revenue agent concluded that petitioner had sufficient cash             
          at that time to pay the entire tax due for 1990, but not to pay             
          the total of the tax due for each of the remaining years at                 
          issue.  The revenue agent also determined from her examination of           
          petitioner's bank accounts that petitioner had funds available at           




Page:  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