- 4 -
the business of child care.3 Additionally, petitioner's sister
Linda Klyce ran a catering business named Sweets-N-Things
(Sweets), a sole proprietorship.
Special Occasions began to lose money in 1990. In order to
keep Special Occasions operating, the partners sought business
loans from local banks and the Small Business Administration.
The partners were ultimately unsuccessful in obtaining loans.
Petitioner therefore began making cash advances and writing
checks against her credit card accounts in order to finance the
daily operations of Special Occasions. During this time,
petitioner also made cash advances against her credit card
accounts and then lent the money to Special O. Petitioner's
contributions to Special O were purportedly memorialized in
promissory notes signed by Linda Klyce and Barbara Wilson in
their capacity as officers of Special O.
Petitioner made her car, a 1986 Mercury, available to
Special Occasions and Special O for business purposes. Other
businesses, such as Klyce and Sweets, also used petitioner's car.
Additionally, petitioner, her sisters, and petitioner's niece all
used petitioner's car for personal purposes.
3 Petitioner, Barbara Wilson, and Linda Klyce each owned one-
third of Klyce.
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