-11-
prepared a substitute for return with respect to petitioner’s
taxable year 2000.
On April 11, 2003, petitioner filed a document entitled
“Application for Statement of Charges” (April 11, 2003 applica-
tion) with the District Court of Maryland for Anne Arundel
County. In that application, petitioner declared under oath:
Between July 25, 2001 and Aug 8, 2001, Garrett
Mona, Patrick Mona and Nick Mona intentionally misrep-
resented their intent to complete work on our [peti-
tioner’s and Ms. Davis’] house and repair defective
work that existed at that time. As a result of their
intentional misrepresentations, we paid an additional
$120,543.00 to them. We discovered and confirmed the
extent of the structural defects between July & Oct
2002.
On April 22, 2003, petitioner received a copy of a letter
from the Department of Inspection and Permits, Anne Arundel
County, in which it voided the certificate of occupancy that it
had issued with respect to the custom house.
On May 1, 2003, petitioner and Mona Builders entered into a
settlement agreement (May 1, 2003 settlement agreement) with
respect to the custom house litigation. As part of that settle-
ment agreement, Mona Builders agreed to purchase the custom house
from petitioner and Ms. Davis for $1,500,000. On May 29, 2003,
pursuant to the May 1, 2003 settlement agreement, petitioner and
Ms. Davis transferred the custom house to Mona Builders in
3(...continued)
years 1995, 1996, 1998, 1999, and 2000.
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