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all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
At the time the petition was filed, petitioner resided in
Golden, Colorado.
Petitioner has a background in property management and has
completed 1 year of college. Petitioner has no children.
In September of 1986, petitioner met John McKnight (John).
In 1987, John and his then wife Sally Overton (Overton) divorced.
Shortly thereafter, petitioner and John began dating. John has a
son from his marriage to Overton.
John acted as a sales representative for construction
product manufacturers. John operated his business as a sole
proprietorship under the name of McKnight and Associates.
As petitioner and John’s dating relationship developed,
petitioner allowed John to use petitioner’s personal credit cards
to pay a number of John’s business expenses. Initially, John
promptly repaid petitioner so that petitioner could timely make
her credit card payments.
In 1990, John asked petitioner to work in his business.
John told petitioner that he needed her help to expand the
business and that he would pay petitioner the same amount that
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Last modified: May 25, 2011