-14-
1992, Kortava, a native of Leningrad, lived and worked as a
banker in the former Soviet Union. Kortava founded his own bank
and monetary fund. Kortava made approximately $500,000 through
foreign currency exchange transactions during 1989 and 1990.
On September 10, 1990, Kortava and petitioner agreed that
Kortava would transfer $500,000 to petitioner for real estate
investments in the United States. Petitioner was to manage these
funds. Within days, they modified their agreement. Kortava
decided it would be better to organize a corporation and transfer
his funds to it and not to petitioner personally.
Coastline Limited (Coastline), a California corporation, was
incorporated for the purposes of real estate, consulting, and
marketing trade. Kortava nominally was the chief financial
officer of Coastline. Coastline never filed a Federal income tax
return.
Kortava transferred by wire to petitioner the following
amounts:
Date Amount Transferred to1
10/22/90 $ 20,000 6130
11/19/90 38,000 61302
11/19/90 20,000 61302
12/12/90 200,000 6250
12/21/90 14,544 61302
$292,544
01/29/91 7,046 6130
04/17/91 85,000 6130
05/31/91 80,000 6130
07/11/91 29,985 6130
07/12/91 35,000 61303
10/03/91 1,581 6130
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