American Valmar International Ltd., Inc., et al. - Page 1

                                        T.C. Memo. 1998-419                                              

                                      UNITED STATES TAX COURT                                            

            AMERICAN VALMAR INTERNATIONAL LTD., INC., ET AL.,1 Petitioners v.                            
                         COMMISSIONER OF INTERNAL REVENUE, Respondent                                    

                  Docket Nos.  11776-95, 11777-95,  Filed November 19, 1998.                             
                              16318-96, 16319-96.                                                        

                        An individual and his wholly owned corporation                                   
                  each received wire transfers of U.S. dollars from                                      
                  within the former Soviet bloc of countries.  Ps claim                                  
                  that the wire transfers to the individual were part of                                 
                  a ruble hoard accumulated before he came to the United                                 
                  States and the wire transfers to the corporation were                                  
                  deposits received in the corporation’s business as a                                   
                  commission agent.  R treated all the wire transfers as                                 
                  gross income to the corporation and treated the amounts                                
                  received by the individual as distributions from the                                   
                  corporation.  R also disallowed certain deductions of                                  
                  the corporation and imposed accuracy-related penalties                                 
                  and delinquency additions.                                                             
                        Held:  Wire transfers to corporation and some of                                 
                  wire transfers to the individual are gross income to                                   

            1     The cases of the following petitioners are consolidated                                
            herewith:  Valeri Markovski, docket Nos. 11777-95 and 16319-96;                              
            American Valmar International, Ltd., Inc., docket No. 16318-96.                              

Page:   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