Marian Wilson - Page 5




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               The Oakland boutique closed its doors in 1994.  Another                
          boutique, which Special Occasions had opened in Baton Rouge,                
          Louisiana, in 1994, closed in 1997.                                         
               At the time of trial, petitioner was employed by the                   
          Internal Revenue Service (IRS) as an acting Appeals officer.                
          Petitioner has been employed by the IRS since 1974 and has worked           
          at different times as a tax auditor, revenue agent, and technical           
          analyst.                                                                    
               Petitioner was told by her supervisors at the IRS that she             
          could not maintain the books and records of Special Occasions,              
          Special O, or Klyce "as a condition of [her] employment with the            
          IRS".  The books and records of Special Occasions, Special O, and           
          Klyce were maintained by Linda Klyce.  Although petitioner did              
          not maintain the books and records of either Special Occasions or           
          Special O, petitioner wrote most of the checks drawn from Special           
          Occasions and Special O's shared checking account at Wells Fargo            
          Bank.                                                                       
               Petitioner reported nonpassive losses from Special O on                
          Schedules E of her Federal income tax returns in the amounts of             
          $6,875,4 $8,345, and $13,777 for the 1991, 1992, and 1993 tax               
          years, respectively.  Petitioner also reported nonpassive losses            



          4    Though petitioner reported 1991 losses from Special O in the           
          amount of $6,875 on her Federal income tax return, the parties              
          stipulated 1991 losses from Special O in the amount of $6,895.              




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