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submissions that she made to the IRS after she filed that form.30
Moreover, petitioner had no hesitation in allowing the children
to stay with Mr. Krasner during virtually all of the trips that
she took alone during 1999. Nor did petitioner have any hesita-
tion in allowing the children to stay with Mr. Krasner pursuant
to the custodial order that was in effect at most relevant times
after she and Mr. Krasner legally separated on October 13, 1999,
under which, for each 28-day period during the year (excluding
the summer when certain of the children attended camp), the
children were to spend 18 days with Mr. Krasner. If petitioner’s
claim that Mr. Krasner “abused drugs and alcohol, which resulted
in aberrant behavior” were true, we do not believe that she would
have left the children with Mr. Krasner during virtually all of
the trips that petitioner took alone during 1999, and we believe
that she would have asked the Montgomery County Court of Common
Pleas to modify the custodial order so that the children were not
in Mr. Krasner’s custody for 18 out of each 28-day period during
the year (except the summer). Furthermore, petitioner had no
hesitation in making complaints about Mr. Krasner to the
Haverford police department. If petitioner’s claim that Mr.
Krasner “abused drugs and alcohol, which resulted in aberrant
behavior and his abusive treatment of her” were true, we believe
30In response to a question in petitioner’s Form 886-A
asking whether petitioner was subject to any marital abuse during
1998, petitioner stated: “See Report”. Petitioner did not
attach any report to petitioner’s Form 886-A.
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