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Bbefor Boudin, Stahl and Lipez, Circuit Judges.

The Staab Agency (“Staab”) acts as an agent for out-of-state trucking companies seeking to register trailers in Maine. Shirley St. Pierre, the appellant in this case, owned all of Staab after purchasing it from its previous owner in 1991. Under her guidance, the company prospered, growing from approximately four employees and 4,000 customers in 1991 to 17 employees and 37,500 customers in 2002. As the sole owner, St. Pierre regularly used company income to pay personal bills and for other personal purposes–not objectionable so long as she reported the income on pertinent tax returns.

The IRS randomly audited Staab’s fiscal year 2000 returns in March 2002; the audit gave rise to suspicions and was later expanded to include other returns by Staab and St. Pierre herself. Because Staab is a Subchapter S corporation, its income is not taxed to Staab but is attributed to St. Pierre, who must pay taxes on it herself. 26 U.S.C. § 1366(a)(1) (2006). In June 2007, St. Pierre was indicted on three counts of tax evasion, 26 U.S.C. § 7201, and one count of obstructing administration of the internal revenue laws for falsifying documents in an attempt to conceal her prior acts, 26 U.S.C. § 7212(a).

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