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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
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