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transfer was a disbursement of Interrosa’s funds other than the
claim that the proposed finding “is based on the self-serving
testimony of Valeri Markovski.” Although we have doubts about
some aspects of Markovski’s testimony, there was nothing
suspicious about his testimony concerning the transfer. American
Valmar has carried its burden of proving that the transfer was a
disbursement to Interrosa, and we so find. In his notice of
deficiency for 1993, respondent states that he is disallowing
some of the purchases claimed on the grounds that such amounts
were not for ordinary and necessary business expenses or were not
paid for the purposes designated. We assume that the transfer is
covered by the purposes-designated-language in respondent's
notice, and, since we have found that the transfer was for the
purposes designated, we do not sustain the deficiency to the
extent it is attributable to the transfer.
Petitioners' second claim relates to the $24,500 wire
transfer to Mila Panarey, which they claim was a disbursement at
the direction of Interrosa. We found Markovski’s testimony
unconvincing with respect to that transaction and conclude that
petitioners have failed to carry their burden of proving that the
Mila Panarey transfer was a disbursement at the direction of
Interrosa.
In addition to the two claims with respect to 1993,
petitioners also claim credit for the $57,137 spent with respect
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