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their wives went on a vacation to Rio de Janeiro. The trip cost
approximately $900 to $1,000 per person. Wilson gave Grove cash
for the Wilsons' fares.
Petitioner Giongo
On December 14, 1982, Giongo purchased 22 acres of
undeveloped real property in Huntington Mills, Pennsylvania, for
the purchase price of $13,650. Giongo made an initial payment of
$3,650, plus $473 in closing costs, and undertook a $10,000
purchase money mortgage for the balance, with monthly payments of
$155.27. The property was titled in the names of Giongo and his
wife. The Giongos later located a trailer and constructed a dirt
road on the property.
On November 25, 1983, Giongo purchased 30 shares of AT&T
stock in the name of Ronald V. Giongo, Sr., custodian for Ronald
V. Giongo, Jr., for the amount of $1,955.67 through William
Johnson at Hopper Soliday.
Petitioner Cattalo
Cattalo purchased MCI stock in his son's name. By December
1981, Cattalo had purchased at least $5,000 of PECO stock in the
name of James G. Cattalo, custodian for James G. Cattalo, Jr.
Cattalo was the payee of a money order in the amount of $2,000
dated January 7, 1982. On January 8, 1982, Cattalo deposited
$3,500 in cash into his bank account. On December 14, 1982,
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