Douglas V. and Magdalene Merante - Page 4

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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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