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Petitioner signed a check dated December 17, 1993, in the
amount of $140 that was drawn on the MZ Trading account and made
payable to “B/A” and negotiated it to make a payment against the
balance due on his Master Card account No. 5273-0298-7013-4366.
At a time after the year 1993 that is not disclosed by
credible evidence in the record, petitioner and Mr. Guterman
prepared most, if not all, of a handwritten document dated August
5, 1999, that lists a series of transactions in which petitioner
claims MZ Trading engaged during 1993. (We shall refer to the
handwritten document dated August 5, 1999, as MZ Trading’s
purported 1993 transaction summary.) For each transaction listed
on MZ Trading’s purported 1993 transaction summary, entries
appeared under columns headed “cost”, “sold”, “profit”, and
“expenses”. Numbers and handwriting that is largely illegible
appeared under each of those columns.
Felix Vulis
During at least the years at issue, petitioner participated
in various income-producing activities with Felix Vulis (Mr.
Vulis) and certain organizations with which Mr. Vulis was associ-
ated.
During at least 1992 and 1993, Mr. Vulis was chief executive
officer of Amuke4 Group of Companies (Amuke Group), and Slava
Averbach (Mr. Averbach) and Alex Ferrer (Mr. Ferrer) also partic-
4The word “Amuke” stood for “America Ukraine”.
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