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they paid Wilson Swimming Pools more than $14,000 and a patio and
barbeque for which they paid more than $3,300.
During January 1989, Mr. Katerelos purchased a 1985 Honda
Accord for his daughter Anneta. In the application for insurance
for that car, dated January 16, 1989, Mr. Katerelos was listed as
the driver of the car for 60 percent of the time, Ms. Katerelos
was listed as the driver for 20 percent of the time, and his
daughter Anneta was listed as the driver for 20 percent of the
time. In fact, that car was primarily driven by petitioner's
daughter Anneta after it was purchased.
Petitioners borrowed $9,000 in May 1989 from Valley National
Bank. They paid off that loan by making a principal payment of
$6,000 during August 1989 and two principal payments totaling
$3,000 during November 1989.
In an application for insurance for a 1987 Chevrolet S-10
Blazer, dated June 10, 1991, petitioners were listed as the
owners of the vehicle and Mr. Katerelos was listed as the driver
of that vehicle for 30 percent of the time, Ms. Katerelos was
listed as the driver for 50 percent of the time, and petitioners'
son John was listed as the driver for 20 percent of the time. In
fact, that vehicle was primarily driven by petitioners' son John
after it was purchased.
From 1988 to 1992, Mr. Katerelos was a 50-percent owner of
Kefalonia, Inc. (Kefalonia) that operated a restaurant called
Dolce Vita East. Mr. Katerelos' original investment in Kefalonia
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