- 15 - 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 findPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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