Carlye A. Christianson - Page 20




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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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