Donald Ferry and Sharon Ferry - Page 14

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            personal checkbook.7  In fact, Mrs. Ferry testified under the                                  
            assumption that this was their personal, joint bank account.                                   
                  Petitioners deposited $22,503 into the account in 1987 and                               
            $12,175 in 1988.  The account was not supposed to contain any                                  
            proceeds from the Iron Hill or Wayanne.                                                        
            I.H.R-L Bank Account                                                                           
                  In 1985, petitioner opened a checking account at Second                                  
            National Federal Savings Bank in the name of I.H.R-L LTD (IHRL).                               
            Although I.H.R-L is an abbreviation for Iron Hill Restaurant-                                  
            Lounge, restaurant funds were not supposed to be deposited in                                  
            this account, but in the MIT account.  Wilberding did not have                                 
            signature authority on the IHRL account--in fact, he did not know                              
            it existed.  Petitioners' home telephone number and home address                               
            were listed on the IHRL account, and monthly bank statements were                              
            sent there.  Petitioner made deposits and had sole check-signing                               
            authority.                                                                                     
                  Petitioner deposited $103,514 into the account in 1987 and                               
            $47,458 in 1988.   No one but petitioner used this account.                                    
            R.E.P., Ltd.                                                                                   
                  In February 1988, petitioner opened a checking account at                                
            Second National Federal Savings Bank in the name of R.E.P., Ltd.                               
            (REP).  Petitioner listed his home telephone number and home                                   


            7  There is no evidence that petitioner's parents used the                                     
            account or, indeed, even knew of it.                                                           




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