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the years at issue, thereby establishing a six-year pattern of
substantial and consistent understatement of income. Petitioner
was convicted under section 7203 for failing to file her return
for 1990. In the plea agreement relating to her conviction under
section 7203, petitioner admitted that she also willfully failed
to file returns for 1987, 1988, and 1989, and thereby failed to
report a tax liability of approximately $39,753. Except for
certain estimated tax payments for 1987, petitioner failed to
make required estimated tax payments for the years at issue.
Petitioner gave inconsistent and implausible explanations of her
behavior to the revenue agent and the special agent during their
examination of the years at issue. For example, she stated
variously that she filed her returns for the years at issue, that
respondent must have lost those returns, that if those returns
were not filed, Mr. Golemb was at fault because he was supposed
to have filed them, and that she filed her 1985, 1986, and 1990
returns, but Mr. Golemb filed her 1987, 1988, and 1989 returns.
At trial, petitioner offered similar explanations of her behavior
that the Court did not find credible. We do not believe, inter
alia, petitioner's explanation at trial, which she also gave to
the Service's agents, that she thought her return preparer, Mr.
Golemb, would sign and file her returns for the years at issue.
Based on our examination of the entire record in this case,
we find that respondent has established by clear and convincing
evidence that petitioner intended to evade tax for each of the
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