Donald Ferry and Sharon Ferry - Page 15

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            address on the account, and monthly bank statements were sent to                               
            him there.  Petitioner had sole check-signing authority.                                       
                  During 1988 petitioners deposited $56,224 into the account.                              
            No proceeds from the Iron Hill or Wayanne were supposed to have                                
            gone into this account.                                                                        
                  REP may stand for Real Estate Plus.8   Petitioner was the                                
            actual and beneficial owner of R.E.P., LTD.   Throughout 1987 and                              
            1988, petitioners' home utility bills were in the name of R.E.                                 
            Plus.   This was simply another name for petitioner.                                           
                  We find and hold that petitioners had unreported income of                               
            $130,232 for 1987 and $85,231 for 1988.                                                        
                  Petitioner did not cooperate during the audit.  Although                                 
            requested to do so, he did not turn over any personal records to                               
            respondent.  He refused to pick up certified mail from the post                                
            office.  Moreover, he made false statements to respondent's                                    
            agent, Joanne Griffin.  He claimed he had no bank accounts, no                                 
            credit cards, and no financial interest in any business during                                 
            1987 and 1988.                                                                                 
                                                 OPINION                                                   
                  The theme of this case could well be: "Oh, what a tangled                                
            web we weave when first we practice to deceive."9  To that end,                                


            8 REP may also stand for "Restaurant Equipment Properties".                                    

            9 Sir Walter Scott, "Marmion", canto VI, st. XVII (Little                                      
            Brown & Co. 1857).                                                                             



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