Clyde E. Owens and Marie W. Owens - Page 4

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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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