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Submitted January 25, 2011

Before THOMPSON, Associate Judge, and FERREN and FARRELL, Senior Judges.

This appeal concerns the meaning of an ambiguous clause of a plea agreement by which appellant would – and did – plead guilty to non-willful failure to file sales tax returns and agreed, as a condition of her probation, to pay penalties in addition to the taxes she owed. Construing the disputed clause in her favor, as we must, we hold that she must be given the opportunity to challenge the government’s proof that her non-filings were “willful” and thus subject to the penalties imposed.

 
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