- 39 -
In support of her contention that she did not significantly
benefit from the unpaid assessment for each of the years at
issue, Ms. Collier relies on brief on Ms. Stotts’ statement
quoted supra note 17, in which Ms. Stotts states, inter alia,
that she lent Ms. Collier undisclosed amounts of money and that
“[Mr. Collier] did not always give her [Ms. Collier] enough money
to cover their bills” that Ms. Collier was responsible for
paying. We are unwilling to rely on the foregoing vague state-
ments of Ms. Stotts to establish that Ms. Collier did not signif-
icantly benefit within the meaning of section 4.03(2)(c) of
Revenue Procedure 2000-15 from the unpaid assessment for each of
the years at issue. We have rejected above Ms. Collier’s conten-
tion that Mr. Collier handled, and prevented her from participat-
ing in, their financial and tax matters. We have found above
that (1) at all relevant times Ms. Collier was responsible for
paying at least some of the bills of Mr. Collier and herself,
although she did not always have enough money to pay those bills
and that (2) during periods throughout 1987-1991 Ms. Collier and
Mr. Collier maintained a joint checking account. We find on the
instant record that the facts that Ms. Stotts lent Ms. Collier
undisclosed amounts of money and that Ms. Collier did not always
have enough money to pay the bills that she was responsible for
paying are not determinative of whether Ms. Collier significantly
benefited from the unpaid assessment for each of the years at
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