George J. and Sophia Mantakounis - Page 9




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          to leading questions by his counsel, and his testimony on cross-            
          examination was vague and evasive.                                          
               Petitioners argue that a different result in this case would           
          have followed if respondent had interviewed J. Mantakounis prior            
          to his death regarding the loan.  Presumably, petitioners believe           
          that J. Mantakounis’s testimony would have proved the existence             
          of the loan.  We are not required, however, to accept self-                 
          serving, unverified, and uncorroborated statements of petitioner            
          or of his parent.  Tokarski v. Commissioner, 87 T.C. at 77; see             
          Cluck v. Commissioner, 105 T.C. 324, 338 (1995).  Considering the           
          belated and inconsistent explanations provided by petitioner                
          before and during trial, we do not accept his testimony.  We                
          uphold respondent’s determination that the $105,000 was                     
          unreported income.                                                          
          Addition to Tax and Penalty                                                 
               Respondent determined an addition to tax for failure to                
          file timely under section 6651(a)(1) and an accuracy-related                
          penalty for substantial understatement under section 6662(a).               
          Petitioners have presented neither evidence nor argument                    
          regarding the addition to tax and penalty.                                  
               Respondent determined the addition to tax for late filing              
          because, although petitioners were granted an extension to file             
          until October 15, 1992, they did not file until January 21, 1993.           
          To escape the addition to tax for filing late returns,                      






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