American Valmar International Ltd., Inc., et al. - Page 15

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            seeming inconsistencies prove that the customers did not exist or                            
            that American Valmar had no obligation to them.  Indeed, we find                             
            respondent’s wholesale rejection of petitioners’ proof, even as                              
            to the existence of the customers, inconsistent with respondent’s                            
            requiring American Valmar to include in gross income for each                                
            year only the excess of the American Valmar deposits received                                
            over purchases made and commissions earned during such year.                                 
                  Petitioners rely principally on Markovski’s testimony, which                           
            is uncorroborated, they say, because of business conditions in                               
            the former Soviet Union.  We give petitioners the benefit of the                             
            doubt with respect to business conditions in the former Soviet                               
            Union.  Nevertheless, in some respects we found Mr. Markovski                                
            credible and in some we did not.  American Valmar spent at least                             
            $57,137 for home furnishings delivered to a condominium apartment                            
            (the condominium) that Markovski owned and in which he lived.                                
            That amount was charged to contracts payable, and Markovski                                  
            testified that the expenditure was made at the direction of                                  
            Diapazon to outfit a bedroom as living space and office for                                  
            Diapazon employees visiting the United States.  After supposedly                             
            outfitting the condominium for Diapazon, Markovski sold the                                  
            condominium, with many of the improvements left behind.                                      
            Petitioners have not explained what happened to Diapazon’s                                   
            interest in the condominium.  We did not find Markovski’s                                    
            testimony, or the testimony of his wife, Lina, credible with                                 
            respect to the condominium transaction.  Also, we did not find                               




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