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We do not find that the testimony on which Ms. Collier
relies establishes her contentions that Mr. Collier handled, and
prevented her from participating in, their financial and tax
matters and never informed her of any unpaid taxes. Moreover, we
found Ms. Collier’s testimony to be self-serving, conclusory,
vague, inconsistent, and/or questionable in certain material
respects, and we shall not rely on it to establish her position
in this case. Nor do we find that Ms. Stotts’ statement estab-
lishes as facts that Mr. Collier handled, and prevented Ms.
Collier from participating in, their financial and tax matters
and never informed her of any unpaid taxes.18
We have found that (1) Ms. Collier and Mr. Collier jointly
filed a tax return for each of the years 1987 through 1991;
(2) at all relevant times Ms. Collier and Mr. Collier kept
information relating to their financial and tax matters in one
place and had access to that information; (3) at times throughout
1987-1991 Ms. Collier and Mr. Collier discussed their financial
and tax matters; (4) at all relevant times Ms. Collier was
18Ms. Stotts’ statement establishes that at an undisclosed
time Mr. Collier informed Ms. Collier that they were having
problems with the Service and that Ms. Collier was involved with
financial matters of Ms. Collier and Mr. Collier at least in that
Ms. Collier was responsible for paying at least certain of their
bills, although she did not always have enough money to pay those
bills. The assertion in Ms. Stotts’ statement that “Sandrus [Ms.
Collier] told him [Mr. Collier] she had never been involved with
the filing of their taxes before so why was he so upset now” is
nothing but a recitation of what Ms. Collier stated at an undis-
closed time to Mr. Collier in the presence of Ms. Stotts.
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