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for each such year.
In support of her position that the knowledge or reason to
know element is present in the instant case, Ms. Collier contends
on brief that Mr. Collier handled, and prevented her from partic-
ipating in, their financial and tax matters and never informed
her of any unpaid taxes. In an attempt to establish those
contentions as facts, Ms. Collier relies on brief on her own
testimony and the unsworn statement of Christine Stotts (Ms.
Stotts) (Ms. Stotts’ statement), which the parties stipulated
“states her [Ms. Stotts’] personal knowledge of the relationship
between petitioner [Ms. Collier] and her ex-husband [Mr. Col-
lier].”17
17Ms. Collier relies on the following portion of Ms. Stotts’
statement:
After Sandrus and her former husband Clai, moved
to northern Virginia, there were many occasions,
Sandrus and her son would come stay with me for a
couple of days, and other times I would have to loan
her money. Clai did not always give her enough money
to cover their bills. On one occasion while visiting
her, Clai came in and started an argument about their
finances. He was especially upset on receiving a certi-
fied letter from the IRS. He blamed her because he was
late with their taxes. Sandrus told him she had never
been involved with the filing of their taxes before so
why was he so upset now. When she asked to be a part
of his decision making he told her she was too stupid
to understand and he was not about to begin teaching
her now. Their argument was a little too nerve rat-
tling for me so I left. However, two or three hours
later, she called to ask could she stay with me for a
while. Sandrus was afraid of Clai, but stayed in the
marriage as long as she did for their son.
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