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FINDINGS OF FACT
During the years at issue, petitioner was a general partner
with a 32-percent interest in Special Occasions, a partnership.1
Petitioner and her sisters formed Special Occasions in 1983 for
the purpose of manufacturing and selling women's large-size
garments through their boutique in Oakland, California.
Petitioner also owned a one-third interest in Special O,
Inc. (Special O), an S corporation.2 Special O was incorporated
in 1990 to sell women's large-size garments through the Oakland
boutique, in effect dividing manufacturing and sales
responsibilities between Special Occasions and Special O.
Special Occasions and Special O were located in the same building
with the boutique and shared offices. Special O's inventory
included both garments produced by Special Occasions and garments
purchased from outside suppliers.
Petitioner also owned a one-third interest in Klyce Day Care
(Klyce), a partnership which, as its name suggests, engaged in
1 Special Occasions had four partners during the years at
issue, all of them sisters. Petitioner, Barbara Wilson, and
Linda Klyce each owned 32 percent of Special Occasions; another
sister, Faye Oatis, owned 4 percent.
2 The other shareholders included Barbara Wilson and Linda
Klyce, who each held a one-third interest. Petitioner was the
president of Special O, Barbara Wilson was the vice president,
and Linda Klyce was the secretary and treasurer. Faye Oatis was
neither a shareholder nor an officer of Special O during the
years in issue.
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