Douglas V. and Magdalene Merante - Page 6

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            partnership agreement made no provision with regard to capital                            
            contributions to the partnership, nor any reference to the                                
            advances made by petitioner to Sheldon prior to the date of the                           
            document.  Nevertheless, Sheldon and petitioner signed a document                         
            entitled "Cancellation of General Partnership Agreement and                               
            Partnership Agreement" as of April 30, 1989.                                              
                  On January 30, 1990, petitioner transferred a car to Sheldon                        
            in return for a check in the amount of $2,900.  In the memorandum                         
            portion of the check is written "Time To Share repayment on                               
            loan."  The check was returned for insufficient funds, and                                
            Sheldon has never made good on the check, nor has he returned the                         
                  On June 18, 1990, petitioner purchased an "official check"                          
            in the amount of $2,500 payable to Sheldon.  On that date,                                
            Sheldon and Merante signed a document entitled "AGREEMENT" which                          
                  In return for a loan this day by [petitioner] to [Sheldon]                          
                  of $2,500 and for other loans which together with the herein                        
                  referred to load [sic] total $27,000, [Sheldon] promises to                         
                  repay the entire total of $27,000 to [petitioner] no later                          
                  than Wednesday, June 27, 1990.                                                      
                  On July 25, 1990, petitioner gave Sheldon cash of $1,068.                           
                  On October 9, 1990, Sheldon signed a document entitled                              
            "PROMISSORY DEMAND NOTE" in which he agreed to repay a loan to                            

            have had some connection with the paint activity referred to in                           
            the partnership agreement.                                                                

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