Lawyers for dealer Mary Boone, the owner of the eponymous gallery with two locations in New York who pleaded guilty to two counts of filing false federal tax returns last September, have asked for her to be spared prison time, claiming that childhood trauma led to her tax fraud. A memorandum by Boone’s lawyers, Robert S. Fink and Michael Sardar, filed last month to Manhattan judge Alvin K. Hellerstein, asks that she be sentenced to home confinement, up to one thousand hours of community service, and probation, reports the New York Times. The two counts could mean a maximum of six years in prison.

Early childhood traumas—including the loss of her father at the age of three, which resulted in the family’s “abject poverty” and grief—fueled her drive to succeed, wrote the lawyers.

“Boone’s psychological fragility and impaired reality testing—especially with regard to her perception of the actions and intentions of others—will likely significantly impair her adjustment to incarceration and render her vulnerable to increased depression, anxiety, suicidal ideation and further psychological decompensation in prison,” reads the lawyers’ statement. “Behind the facade of success and strength lies a fragile and, at times, broken individual.”

Testimonies from Boone’s psychotherapist and reports from psychological examinations also detail her struggles with mental health, including drug and alcohol abuse, post-traumatic symptoms, suicidal thoughts and attempts, and anxiety. Over one hundred character references from colleagues, family, and friends, including Ai Weiwei and collector Peter Brant, were also in the memo.

According to prosecutors, who have yet to reply to the memo, the gallerist made several false claims on her 2012 federal income tax returns and filed fraudulent individual and corporate tax returns for the years of 2009, 2010, and 2011. She reported that her business lost $52,000 in 2011—while it really made $3.7 million in profit—and that $1.6 million in personal expenses were business deductions. Boone has since paid $6.9 million in taxes, interest, and penalties to the Internal Revenue Service and is “repentant and remorseful,” write her lawyers.

Geoffrey S. Berman, the United States attorney in Manhattan, said that Boone was trying to play “a shell game” with bank accounts so that she wouldn’t have to declare her assets. “As Boone has learned, tax laws are not abstract.”

The sixty-six-year-old, known for championing artists such as Ross Bleckner, Eric Fischl, David Salle, and Julian Schnabel at the start of their careers, opened her first gallery, a ground-floor space at 420 Broadway in SoHo, in 1977. Since then, the gallery has moved to Fifth Avenue and Fifty-Seventh Street. Boone opened a second location in 2000, at 541 West Twenty-Fourth Street. She is scheduled to appear in court this month for sentencing.