Leo and Alla Goldberg - Page 19

                                        -19-                                          
          Business School                                                             
               Petitioner operated the business school as a sole                      
          proprietorship under the name Coastline Ltd.  The business school           
          was formed to send American instructors to Russia to train                  
          Russian business students in the areas of economics,                        
          international marketing, general management, and comparative                
          international management.                                                   
               Petitioners reported all of the income and expenses of the             
          business school on their Schedule C.  Petitioner received a total           
          of $34,544 from Kortava in 1990 for use in the business school.             
               Petitioner, d/b/a Coastline, Inc., entered into a contract             
          with Advanced Education Systems, Inc. (AESI contract).                      
          Petitioners paid at least $20,033 of expenses incurred under the            
          AESI contract with funds from Dean Witter account number 37733,             
          including the following:                                                    
               Date                 Payee              Amount                         
               03/15/91       Carrousel Tour Travel    $  830                         
               04/11/91       AESI                     4,000                          
               04/23/91       Carrousel Tour Travel    7,391                          
               06/02/91       AESI                     4,000                          
               08/28/91       AESI                     1,000                          
               08/29/91       Carrousel Tour Travel    1,104                          
               09/13/91       AESI                     240                            
               09/91          VISA1                    1,468                          
                    1Includes gasoline, meals, lodging, and                           
               entertainment.                                                         
               Petitioner and seven others traveled to Russia as part of              
          the operation of the business school.  At the end of the course             
          in Russia, the top students were invited to visit the United                
          States for additional studies.                                              



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