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payments; and for petitioners' residential utilities and
telephone bills.6
Ferry Associates
In 1984, petitioner opened a bank account at Delaware
Savings and Loan Association in the name of "Ferry Associates".
Petitioner listed his home address as the business address of
Ferry Associates, and monthly bank statements were sent to his
home. He represented to the bank that he was the owner of Ferry
Associates.
The account was opened under the Social Security number (but
not the name) of petitioners' son, Sean Ferry. In 1984,
petitioners' sons were 10 and 6 years old.
Petitioners, along with petitioner's parents, had check-
signing authority for this account and, in fact, used it as their
6 Specifically, we find that petitioners were the owners of
a 1985 Mercury Marquis financed through Wilmington Trust Co.
Petitioner's father was not the owner. Petitioners bought the
car, drove it, obtained insurance for it, and kept it at their
house. Thus, payments to Wilmington Trust in the amount of
$2,250 are income to petitioners.
We also find that petitioners were the beneficial owners of
their residence at 404 Arbour Dr., Newark, Del., where they have
lived since 1982. Specifically, we find that the house was not
owned by petitioner's brother-in-law, David Rowan, by
"Investments Plus, Inc." or by "Iron Hill Investments, Inc." or
by any other entity. Thus, mortgage and tax payments made to
First Federal Savings and Loan totaling $3,249.44, from checks
drawn on the MIT account, were for petitioners' personal expenses
and are income to petitioners, as are payments of telephone and
utility bills at that address.
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