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Mrs. Owens borrowed $20,000 from Liberty Savings Bank on
June 15, 1989. The interest on that loan was $2,027.37 in 1990.
Mr. and Mrs. Owens were required to have life insurance to
get an SBA loan. During the years in issue, they owned two cars:
a Lincoln and a Pontiac Sunbird. During those years, they also
owned a 1989 low boy trailer, a 1989 White tractor, and a 1989
tanker truck.
2. Ms. Feltrinelli
Petitioner Janet L. Feltrinelli (Ms. Feltrinelli) lived in
Tallapoosa, Georgia, when she filed her petition in these cases.
In 1989 and 1990, she was a self-employed single parent of a
young child.
B. Petitioners' Businesses
1. Background
In 1989 and 1990, Mr. Owens operated Big O Truck Stop, Ms.
Feltrinelli operated Big O Barbecue, and Mrs. Owens operated
Burger Chick. Big O Truck Stop and Big O Barbecue are in the
same building. Mr. Owens and Ms. Feltrinelli each have an office
in the building in which the Big O businesses are located. Mrs.
Owens has an office in the Owens' residence. Mr. and Mrs. Owens
deducted some of their residential utilities expenses as a
business expense.
Petitioners worked 70 hours a week at the businesses. They
did everything required to operate the businesses, such as make
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