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B. Petitioners’ Background
In 1965, after graduating from high school in Lake Stevens,
Washington, Wayne Berry (petitioner) went to work at a sawmill.
After working at the sawmill for 5 months, he was drafted into
the U.S. Army. The Army sent him to a military school in Georgia
for training to work with helicopters. Then he served in Vietnam
for 3 years as a door gunner on a medivac helicopter. In 1968,
he returned to Lake Stevens and married Pamela Berry, whom he had
met in high school. With the assistance of his father, in Lake
Stevens he started a business that manufactured various interior
house products such as moldings, door jambs, window trim, and
base shoe. Petitioner’s father had owned and sold a similar
business in California. In 1973, petitioner purchased his
father’s interest, taking full control of the business.
Petitioner operated it as Apex Wood Products Corp. (Apex). At
the time of trial, petitioner owned 98 percent of the stock of
Apex.
During the years at issue, Pamela Berry was a flight
attendant for United Airlines. She was married to petitioner
until 1992, when their divorce was finalized.
Petitioners were financially successful. During 2 of the 3
years in issue,2 they received total income (excluding claimed
2Petitioners’ 1979 Federal income tax return was not part of
the record.
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