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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 of
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