George and Myrsini Stotis - Page 16

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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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