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Amuke Group during 1992 “Nonemployee compensation” of $5,872.
The record does not disclose whether Amuke Group issued Form 1099
to petitioner for 1993.
At a time that is not disclosed by the record, Mr. Vulis
guarantied repayment of a $15,000 loan that Mr. Ferrer, who was a
business associate of Mr. Vulis at Amuke Group, made to peti-
tioner (Mr. Ferrer’s $15,000 loan). At a time that also is not
disclosed by the record, Mr. Vulis, as the guarantor of Mr.
Ferrer’s $15,000 loan, repaid that loan.
During at least 1993, petitioner participated in certain
income-producing activities with Commonwealth Enterprises,
another business with which Mr. Vulis was associated. Common-
wealth Enterprises, like the Amuke organizations, was engaged in
the purchase of certain merchandise for resale to customers
located in the former Soviet Union. Petitioner conducted busi-
ness with Commonwealth Enterprises in a manner similar to the
manner in which he conducted business with the Amuke organiza-
tions; that is to say, in general, petitioner located certain
merchandise on behalf of Commonwealth Enterprises that it be-
lieved it would be able to resell at a profit to its customers,
and Commonwealth Enterprises compensated petitioner for his work
by paying him a portion of the profit from the resale of such
merchandise.
Included within the total deposits during 1992 into peti-
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