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Petitioners assigned error to respondent’s adjustments, claiming
that the Markovski deposits constituted the tax free receipt of a
substantial hoard of rubles (the ruble hoard) accumulated before
Markovski emigrated to the United States.
Petitioners rely principally on Markovski’s testimony and
the testimony of Larisa Saltevskiya (Saltevskiya), a close
personal friend, to establish the existence and size of the ruble
hoard. Petitioners also direct us to a copy of a letter from
R.B. Gevorkian, an executive of Diapazon, dated September 17,
1991 (the Gevorkian letter). The Gevorkian letter states
Diapazon received $1,172,560 from Markovski in November 1990 and
transferred a portion of it to the Chem. 2 account in various
amounts, which include all of the Markovski deposits made in
1991. Respondent relies principally on similarities with respect
to the source and identifying information between the Markovski
deposits and the American Valmar deposits. Respondent
disbelieves Markovski’s and Saltevskiya’s testimony concerning
the ruble hoard, pointing out certain inconsistences in the
testimony of each.
Again, we must weigh petitioners’ less than perfect
testimonial evidence against respondent’s circumstantial
evidence. We have found that Markovski accumulated the ruble
3(...continued)
Apparently, the $57,137 represents the amount American Valmar
spent for home furnishings delivered to Markovski’s condominium
apartment.
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