Marian Wilson - Page 3

                                        - 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.                                                             

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