George J. and Sophia Mantakounis - Page 3




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          $102,876.50 from the Barnett Bank of Pasco County, Florida, and             
          used the remaining funds to obtain a certificate of deposit.                
               Petitioners filed a joint Federal income tax return for 1991           
          reporting taxable income of $42,130.  Petitioners received an               
          extension for filing of their 1991 return until October 15, 1992,           
          and filed their return on January 21, 1993.                                 
               Respondent commenced an examination of petitioners’ 1991               
          joint return in December 1995.  A Form 4789, Currency Transaction           
          Report (CTR), filed by Barnett Bank had shown petitioners’                  
          $105,000 cash transaction, which was not included in petitioners’           
          gross income for 1991.                                                      
               On April 10, 1996, Revenue Agent Helen Moore (Moore)                   
          interviewed petitioner in his accountant’s office.  Petitioner              
          told Moore that, in 1990, he found a box of cash in his father’s            
          house in Philadelphia.  Petitioner then told Moore that he took             
          the money to Florida to purchase the Florida home.                          
               On December 27, 1996, petitioners sold a house they owned in           
          Springfield, Pennsylvania, to their son for $261,500, receiving a           
          check from the title company for $261,536.38.  On January 14,               
          1997, petitioner wrote a check to J. Mantakounis for $154,000               
          from petitioners’ joint bank account.                                       
               Moore issued her report on January 16, 1997, proposing an              
          adjustment to income of $105,000.  After petitioners retained               
          their current counsel, counsel for petitioners told Moore that              






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