George Tsakopoulos and Drousoula Tsakopoulos - Page 5




                                        - 5 -                                         
               On January 21, 2000, Karen Hayes, an escrow assistant at the           
          Placer Title Co., filed a preliminary change of ownership report            
          with the Sacramento County (the County) Assessor’s Office                   
          regarding the transfer of Stockton/Elsie from petitioner to                 
          Angelo.  This form must be filed whenever there is a conveyance             
          of title record in order for the office to assess the property.             
          The box on the report indicating that the transfer was a                    
          “purchase” was checked, and the box for the total purchase price            
          was filled in with $291,483.  Angelo’s name on the report was               
          signed by Ms. Hayes.  No one from Angelo’s office advised Ms.               
          Hayes that the transfer was a “purchase”; however, she filled out           
          the form using the deed given to her by AKT and marked what she             
          believed was “appropriate”.  In addition, the purchase price,               
          which was provided by Angelo’s escrow coordinator, Jean Perry,              
          represented the assessed value of 100 percent of the property,              
          not solely petitioner’s 22.14-percent interest.                             
               On his 1995 tax return, petitioner claimed a $205,949 loss             
          for the abandonment of Stockton/Elsie.  The amount of the loss              
          represented petitioner’s basis in Stockton/Elsie as calculated by           
          petitioner’s tax preparer, Norman Marcoux.  In the notice of                
          deficiency, respondent disallowed the loss.  Respondent                     
          determined that petitioner had not established an abandonment               
          loss, and the loss was not allowable because it was the result of           
          a transaction with a related party.  In addition, respondent                






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011