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            Quinn never attended any meetings related to West Pine. She was                                
            not an officer or director of the corporation. She did not know                                
            whether she was listed as a shareholder.6                                                      
                  Mrs. Quinn knew Mr. Quinn was the secretary of West Pine.                                
            During the years 1979 through 1981, she knew Mr. Quinn visited                                 
            the Pottsville IRS office, but she did not know the purpose of                                 
            his visits. She was familiar, with that IRS office and with Mr.                                
            Clark from her own work responsibilities with the law firm, and                                
            she knew Mr. Quinn had to file West Pine's quarterly payroll tax                               
            returns there. Mrs. Quinn did not learn of West Pine's tax                                     
            problems until she was called to testify at her husband's                                      
            criminal trial in Philadelphia in 1987.                                                        
                  Credit Alliance Action and Aftermath                                                     
                  On June 14, 1982, Credit Alliance Corporation (Credit                                    
            Alliance) entered a default judgment against the Quinns in the                                 
            United States District Court for the Eastern District of                                       
            Pennsylvania on the basis of the Quinns' personal guarantees of                                
            payment of West Pine equipment lease/purchases. Credit Alliance                                
            also entered this judgment in the Court of Common Pleas of                                     
            Schuylkill County, Pennsylvania, on September 7, 1982. Mr. Quinn                               
            had signed Mrs. Quinn's name to the guarantee without her                                      
                  6In 1984, after the years before the Court, two men from                                 
            Philadelphia appeared in her home and insisted that she sign a                                 
            blank stock certificate for West Pine. Mrs. Quinn did not wish to                              
            sign without contacting an attorney but did so under pressure                                  
            from these men and Mr. Quinn. She did not know the purpose of                                  
            this certificate. No evidence of the certificate or its purpose                                
            was presented at trial.                                                                        
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