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hoard before he emigrated from Russia. No purpose would be
served in going into the details of his testimony. We have
considered the inconsistencies pointed out by respondent.
Nevertheless, respondent has no effective rebuttal to much of
Markovski’s narrative of his activities and family history in
Russia. We believe that Markovski did accumulate some
substantial amount of wealth before he emigrated to the United
States. Whether the Markovski deposits comprised all or part of
the ruble hoard is another question. Petitioners offered no good
explanation for the similarities between the Markovski deposits
and the American Valmar deposits. A similar notation--for
equipment contract 14-12-90--accompanies four of the 1991
Markovski deposits, those of April 22, May 24, July 1, and
July 12, 1991, in the amounts of $315,591, $133,800, $52,730, and
$80,200, respectively, and three of the American Valmar deposits,
those of January 25, June 6, and June 21, 1991. The May 23,
1991, Markovski deposit, in the amount of $113,519, carries the
notation: “By order of: SV Interrousa [sic].” The May 31,
1991, Markovski deposit, in the amount of $50,500, carries the
notation: “Beneficiary: American Valmar, Intl Co.” We believe
that the similarities in notation between the April 22, May 24,
July 1, and July 12, 1991, Markovski deposits and certain of the
American Valmar deposits and the notations on the May 23 and
May 31, 1991, Markovski deposits are evidence that those deposits
related to the business of American Valmar. We accord that
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