- 11 - The envelopes in which the income tax returns of American Valmar for the fiscal years in issue were mailed to the Internal Revenue Service reflect the below-listed postmark dates: Taxpayer Period Postmark Date American Valmar 6/30/91 2/12/93 American Valmar 6/30/92 None American Valmar 6/30/93 12/15/94 American Valmar’s income tax returns for 1991, 1992, and 1993, were received by the Internal Revenue Service on February 16, 1993, July 6, 1994, and December 19, 1994, respectively. OPINION I. Introduction The principal issues in this case involve the proper characterization of various amounts received from abroad by wire transfer into bank accounts of petitioner American Valmar International, Ltd., Inc. (American Valmar) and its principal shareholder, petitioner Valeri Markovski (Markovski). Respondent disagrees with petitioners’ claim that the amounts received by American Valmar did not constitute items of gross income because of American Valmar’s obligation to expend those amounts on behalf of its clients. Respondent also disagrees with petitioners’ claim that the amounts received by Markovski did not constitute items of gross income because those amounts were the proceeds of a hoard of rubles accumulated before Markovski emigrated to the United States. Petitioners place substantial reliance onPage: Previous 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