Michael and Patricia Vetrano - Page 6




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             by check, petitioner was not obligated to account to BMAP                
             for the money, and there was no restriction or limitation                
             on petitioner’s use of the money.  He was free to use the                
             money received from BMAP in any way he wished.                           
                  Petitioner married Mrs. Patricia Vetrano in 1991.                   
             During 1993, she was employed at a racetrack in Atlantic                 
             City, New Jersey.  She received a Form W-2 from the                      
             Atlantic City Racing Association for 1993 that reports                   
             wages of $17,561.75.  This amount was reported on                        
             petitioners’ joint return for 1993.                                      
                  Petitioner was previously married to Ms. Teresa A.                  
             Simone.  He had two children from that marriage.  He was                 
             divorced from Ms. Simone pursuant to a divorce action that               
             was commenced in 1987 in the New Jersey Superior Court,                  
             Family Part, Chancery Division.  By order dated May 3,                   
             1988, the divorce court ordered him to pay $200 per week                 
             to Ms. Simone as child support for his two children.  For                
             several years thereafter, including during the years in                  
             issue, petitioner and Ms. Simone engaged in litigation over              
             the amount of child support that petitioner would have to                
             pay and various other matters.  From time to time in that                
             litigation, petitioner was required to document his income               
             by submitting pay stubs and other financial information,                 
             including bank statements, to the divorce court.                         






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