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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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