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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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