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tax under section 6651(a), and (3) whether petitioners are liable
for an accuracy-related penalty under section 6662(a).
Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the year in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Springfield, Pennsylvania, at the
time they filed their petition. Petitioners had been married for
45 years at the time of trial. John T. Mantakounis
(J. Mantakounis), father of George J. Mantakounis (petitioner),
resided in an apartment house in Philadelphia, Pennsylvania,
owned by petitioner’s sister. J. Mantakounis spent his time in
Philadelphia and in Greece. J. Mantakounis died in Icaria,
Greece, on January 16, 2000.
In 1991, petitioners traveled to Holiday, Florida, to
purchase a home. Settlement of the purchase transaction occurred
on March 6, 1991. The purchase price was $160,000, with
$143,746.10 due at closing. In connection with this purchase,
petitioners engaged in a $105,000 cash transaction. On March 4,
1991, petitioners bought a cashier’s check in the amount of
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