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comprising petitioner, Barbara J. Wilson, and Marian Wilson, each
owning a one-third interest.
(2) Special Occasions. This was also a general partnership
organized in 1983 and consisting of petitioner, Marian Wilson,
and Barbara J. Wilson, who each owned a 32-percent partnership
interest, and Faye W. Oatis, who owned a 4-percent interest.
Special Occasions specialized in custom tailoring, including
designs, of clothing and accessories, such as wedding and party
dresses, for what was described as "full-figured" women.
(3) Special O, Inc. This was an S corporation that was
organized in 1990 by petitioner, Marian Wilson, and Barbara J.
Wilson, who each owned one-third of the stock in the corporation
(Special O). The other sister, Faye W. Oatis, had no interest in
Special O. Marian Wilson was president of Special O, Barbara J.
Wilson was vice president, and petitioner was secretary-
treasurer. Special O was organized to conduct sales of the
clothing prepared or manufactured by Special Occasions. In
addition, Special O sold related merchandise. The activities of
Special Occasions and Special O were conducted in the same rented
building that was located in Oakland, California.
(4) Sweets 'N' Things. This was a sole proprietorship owned
by petitioner, which was a catering activity. The only issue as
to this activity is whether, for 1991 and 1992, petitioner is
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Last modified: May 25, 2011