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substantial accumulation of cash.
University Video Wholesale
During the years at issue, petitioner operated a sole
proprietorship under the name University Video Wholesale3 that
engaged in various activities relating to the sale of video
equipment to small retail stores and the purchase for resale of
certain other types of consumer goods such as shoes and handbags.
MZ Trading Company
Around April 1, 1993, petitioner and Mikhail Guterman (Mr.
Guterman) formed a partnership known as MZ Trading Company. MZ
Trading engaged in various activities relating to the purchase in
the United States of certain types of merchandise and the sale of
such merchandise to customers located in Russia and the Ukraine.
During at least part of 1993, a checking account over which
petitioner had signature authority was maintained at Bank of
America in the name of MZ Trading (MZ Trading account).
Included within the total deposits during 1993 into peti-
tioner’s checking account 11804-10677 were the following depos-
its, which included two checks, a portion of each of which was
deposited into that account and a portion of each of which was
3As discussed below, the joint tax returns of petitioner and
Ms. Brodsky for 1991 and 1992 indicated that the name under which
petitioner operated the Schedule C business that he reported in
those returns was Zinovy Brodsky, and their joint tax return for
1993 did not provide the names under which petitioner operated
the two Schedule C businesses that he reported in that return.
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