American Valmar International Ltd., Inc., et al. - Page 17

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            III.  American Valmar Additional Deductions                                                  
                  As stated, respondent increased American Valmar’s gross                                
            income for the years in issue by the excess of the American                                  
            Valmar deposits received during a year over purchases made and                               
            commissions earned during such year.  Respondent disallowed                                  
            certain of American Valmar’s claims of purchases made on behalf                              
            of customers as follows:  $338,793, $104,894, and $449,828 for                               
            1991, 1992, and 1993, respectively.  Respondent has conceded                                 
            $47,500 of the purchases disallowed for 1991 and $50,000 of the                              
            purchases disallowed for 1993, leaving at issue $291,293,                                    
            $104,894, and $399,828 for 1991, 1992, and 1993, respectively.                               
            Although petitioners claim on brief that additional amounts of                               
            purchases were conceded by respondent, they have failed to prove                             
            any additional concessions.  Apparently believing that all other                             
            disallowed purchases have been conceded, petitioners address only                            
            $361,500 of the remaining 1993 disallowance of $399,828.                                     
                  Petitioners first claim that $337,000 of funds attributable                            
            to Interrosa was disbursed during American Valmar’s 1993 taxable                             
            year to a Manufacturer’s Hanover bank account in the name of                                 
            Anatoli Seregin, an officer of Interrosa.  The parties have                                  
            stipulated transfers in that amount during that year to that bank                            
            in that name (the transfer).  In evidence is correspondence                                  
            purporting to be from Interrosa and authorizing American Valmar                              
            to open an account in the name of Anatoli Seregin.  Respondent                               
            offers nothing to rebut petitioners’ proposed finding that the                               




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