American Valmar International Ltd., Inc., et al. - Page 18

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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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