- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011