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lease of that vehicle by giving Gold Key in each of those months
a $549.99 check that he signed, which was payable to Gold Key and
drawn on petitioner’s checking account.
In order to qualify to lease the 1995 Jeep Grand Cherokee
from Gold Key, on December 27, 1994, Ms. Thompson and petitioner
submitted to Gold Key a credit application (Gold Key credit
application). That application indicated that Ms. Thompson was
retired and that Uptime Nutrition employed petitioner. The Gold
Key credit application did not indicate that Weavewood was
applying for credit to lease the 1995 Jeep Grand Cherokee or that
Weavewood was in any way connected with that application.
Sometime in January 1995, Gold Key entered into a lease agreement
(Gold Key lease agreement) with Ms. Thompson and petitioner for
the lease of the 1995 Jeep Grand Cherokee. The Gold Key lease
agreement indicated that Ms. Thompson and petitioner were the
lessee and colessee, respectively. The Gold Key lease agreement
did not indicate that Weavewood was a lessee or colessee or that
Weavewood was in any way connected with that agreement. At no
relevant time was the 1995 Jeep Grand Cherokee Weavewood’s
company vehicle.
Transactions Involving Petitioner and
Checks That Were Payable to Weavewood
July 16, 1996 Checks
On July 16, 1996, after Weavewood terminated petitioner,
petitioner deposited into petitioner’s checking account the
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