Cheryl McKnight - Page 4

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          prior to their marriage.  John titled the new car only in his               
          name.  John told petitioner that he had mistakenly omitted                  
          petitioner’s name from the car title, but John later acknowledged           
          that he had done so intentionally.                                          
               After petitioner married John, John’s spending began to                
          spiral out of control.  John increased the amount and frequency             
          of charges he made on petitioner’s credit cards, and John became            
          increasingly delinquent in payments to petitioner to cover the              
          expenses so charged.  At one point, John’s charges to                       
          petitioner’s credit cards relating to John’s business reached a             
          total outstanding balance of $38,000.                                       
               With her own funds, petitioner eventually paid off a                   
          significant portion of John’s charges to her credit cards.                  
               On December 30, 1993, John incorporated his sales                      
          representative business as MGI/McKnight Group, Inc. (MGI).  An              
          election was filed with respondent to have MGI treated as an                
          S corporation.                                                              
               At John’s insistence, petitioner signed the MGI articles of            
          incorporation, and petitioner, along with John, was listed on the           
          MGI articles of incorporation as a director of MGI.  Petitioner,            
          however, was not aware of the legal significance of signing the             
          MGI articles of incorporation or of being listed as a director.             
               John always made it clear to petitioner that he regarded               
          himself as sole owner of the business and of MGI and that he did            

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