Marian Wilson - Page 4

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          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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