American Valmar International Ltd., Inc., et al. - Page 4

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            principal office in New York, New York, and Markovski resided in                             
            Fort Lee, New Jersey.                                                                        
            Markovski                                                                                    
                  Markovski was born in Dniepepetrovsk, U.S.S.R., in 1945.  In                           
            1989, he emigrated to the United States, and, in 1995, he became                             
            a U.S. citizen.  Prior to emigrating to the United States, he                                
            accumulated a substantial hoard of rubles (the ruble hoard).  The                            
            ruble hoard was, in part, attributable to Markovski’s sale of                                
            Soviet government securities and inherited jewelry.                                          
            American Valmar                                                                              
                  American Valmar, a New York corporation, was organized in                              
            1989.  Markovski is the sole shareholder of American Valmar.                                 
                  During its taxable years here in issue, American Valmar was                            
            engaged as a commission broker, purchasing goods in the United                               
            States for export to customers located in the former Soviet                                  
            Union.  It had four customers:  Video Computer, a Moscow-based                               
            trading company engaged in the sale of electronic goods;                                     
            Diapazon, also a Moscow-based trading company; Interrosa, a                                  
            Ukraine-based trading company; and Kond Petroleum, a company in                              
            the oil business in Siberia.  American Valmar filed Federal                                  
            income tax returns for the years in issue.  On those returns, it                             
            did not report gross sales and cost of goods sold.  The only                                 
            income reported by it was commission income of between 5 and                                 
            8 percent of the dollar amount of purchases made for customers.                              






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