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allocated to payroll went into an account at Delaware Savings and
Loan Association in the name of "D. Ferry or W. Wilberding - MIT
Ltd".5 The account was used for food purchases, car purchases,
and other purchases and supplies used in the course of the
restaurant's business. Both petitioner and Wilberding signed the
card, dated January 16, 1985. Although the address on the
signature card is that of the restaurant, during the years in
issue, bank statements were mailed to petitioner's residence.
The EIN shown on the MIT account statement is 251-23-3914.
Neither petitioner nor Wilberding was paid a salary for his
work at Iron Hill. However, it was petitioner's idea to pay many
of his own and Wilberding's personal expenses from the MIT
account, and this was done.
In 1987, petitioners' personal expenses in the amount of
$8,126 were paid from the MIT account; in 1988, $1,278 was paid.
Checks were written from this account for petitioners' personal
benefit, to Holy Angels parochial school (which petitioners'
children attended); to Macy's, J.C. Penney, and Strawbridge for
credit card purchases; to Wilmington Trust for car payments; to
First Federal Savings and Loan for petitioners' home mortgage
5 MIT stands for Mortgage Investors Trust, which in a prior
lawsuit petitioner admitted was himself.
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