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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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