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his role with Time To Share in this regard was quite vague. The
exact date of petitioner's commencement of activities with Time
To Share was not set forth in the record.
On January 3, 1989, petitioner wrote a check to Sheldon for
$2,500. The memo portion of the check states "Glitter Glaze TTS
startup expenses". It is not exactly clear what was intended by
the phrase Glitter Glaze TTS, although TTS may have referred to
Time To Share, and Glitter Glaze may have had something to do
with Koramics or some other paint enterprise.
Apparently, Time To Share developed cash flow problems and
needed infusions of funds from time to time to maintain its
operating expenses. Sheldon prevailed upon petitioner to assist
with this problem, and it appears petitioner was the sole source
of assistance. On February 6, 1989, and March 23, 1989,
petitioner wrote two checks payable to Sheldon, each in the
amount of $5,000. The memo portion of these checks contains the
phrases "for partnership for Time To Share" and "general
partnership in Time To Share", respectively. No notes or other
documents of indebtedness were signed by Sheldon with regard to
these transactions at this time.
On April 2, 1989, and again on April 7, 1989, petitioner
gave $2,500 cash to Sheldon. On April 2, 1989, Sheldon signed a
document that states:
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