- 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 atPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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