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Petitioner's theory is that it was not his money. He posits
several possibilities: It was Wayanne's money, already taxed.
Or it was a "pass-through" among various entities. Or it was his
father's or his children's money (which petitioner was holding or
investing for them). Or the money came from gifts or loans from
his parents. Or it was the repayment (without his business
associate's knowledge) of "loans" petitioner had made to the
business. Or it was the movement of funds left over from the
settlement of a lawsuit in 1983.
Family Relations
Sharon Ferry attended St. Joseph's College and Duquesne
University and has a degree in nursing. She took a nursing
refresher course in 1988. Aside from the Form W-2 income of $270
reported in 1987, she was employed only as a babysitter for 3
hours per week at $5 per hour during the years in issue.
Since 1982, petitioners have lived at 404 Arbour Drive,
Newark, Delaware. Sharon Ferry's maiden name is Rowan. She has
two brothers, William and David. Neither brother ever mentioned
to Mrs. Ferry that he was the owner of the house where
petitioners reside.
During 1987, petitioners' sons were ages 13 and 9. They
attended Holy Angels parochial school.
During the years in issue, petitioners had only one
telephone line in their house. Although this number was listed
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