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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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Last modified: May 25, 2011