- 16 - petitioner to receive payment pursuant to the surrender agreement, petitioner instructed Seawall to issue certified checks to Mrs. Stotis, Maria, and Evanthia. Spyropoulos attended petitioner's meetings with Signorile, and Spyropoulos interpreted for petitioner. During those meetings, petitioner realized the important differences between the surrender agreement and the sublease agreement. Petitioner produced the sublease agreement which seemingly corroborated his story that he received from Seawall the new apartment rent free for 3 years and nothing else. Petitioner withheld the surrender agreement that contained the provisions for payment of $322,500 by Seawall. Petitioner signed a written statement that he received from Seawall the new apartment rent free for 3 years and nothing else. Spyropoulos read the statement to petitioner before petitioner signed it. We find that petitioner understood the negotiations with Seawall, the surrender agreement, the sublease agreement, the statements he made to Signorile, and the written statement that he signed for Signorile. Petitioner testified that he received tax advice from Spyropoulos. We need not accept uncorroborated testimony at face value if it is questionable, improbable, or unreasonable. Quock Ting v. United States, 140 U.S. 417, 420-421 (1891); Fleischer v. Commissioner, 403 F.2d 403, 406 (2d Cir. 1968). We find petitioner's testimony questionable and improbable. Spyropoulos contradicted petitioner's testimony disclaiming any knowledge ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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