Zinovy Brodsky - Page 78




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          Amuke Group during 1992 “Nonemployee compensation” of $5,872.               
          The record does not disclose whether Amuke Group issued Form 1099           
          to petitioner for 1993.                                                     
               At a time that is not disclosed by the record, Mr. Vulis               
          guarantied repayment of a $15,000 loan that Mr. Ferrer, who was a           
          business associate of Mr. Vulis at Amuke Group, made to peti-               
          tioner (Mr. Ferrer’s $15,000 loan).  At a time that also is not             
          disclosed by the record, Mr. Vulis, as the guarantor of Mr.                 
          Ferrer’s $15,000 loan, repaid that loan.                                    
               During at least 1993, petitioner participated in certain               
          income-producing activities with Commonwealth Enterprises,                  
          another business with which Mr. Vulis was associated.  Common-              
          wealth Enterprises, like the Amuke organizations, was engaged in            
          the purchase of certain merchandise for resale to customers                 
          located in the former Soviet Union.  Petitioner conducted busi-             
          ness with Commonwealth Enterprises in a manner similar to the               
          manner in which he conducted business with the Amuke organiza-              
          tions; that is to say, in general, petitioner located certain               
          merchandise on behalf of Commonwealth Enterprises that it be-               
          lieved it would be able to resell at a profit to its customers,             
          and Commonwealth Enterprises compensated petitioner for his work            
          by paying him a portion of the profit from the resale of such               
          merchandise.                                                                
               Included within the total deposits during 1992 into peti-              






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