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expenses substantiated” that may be deducted from gross income by
petitioner; the amounts of Crocus’s overhead expenses are not
included in the stipulation of facts.
Second, in their briefs, petitioner and respondent each
argue that net profits for foreign trade shows conducted after
December 31, 1994, should be split in the same way net profits
for pre-January 1, 1995, foreign trade shows were split.
Paragraph 20 of the stipulation of facts states that petitioner
contends that any net profits of pre-January 1, 1995, foreign
trade shows were divided equally between petitioner and Crocus,
whereas respondent contends that Crocus received nothing more
than the reimbursement of its direct expenses and overhead.
Respondent contends that petitioner received all net profits from
pre-January 1, 1995, foreign trade shows, which were divided at
the stockholder level of petitioner with Agalarov entitled to 50
percent of such net profits and the remaining 50 percent divided
between Pollak, Tseytin, and Kogan. In addition, petitioner
contends that it and Crocus orally agreed to an equal split of
net profits from foreign trade shows conducted from 1990 to 1996.
Unlike the stipulations with respect to foreign trade shows
conducted during the taxable periods at issue, the record does
not provide enough information regarding the amount of net
profits for the periods before January 1, 1995, to resolve the
contentions of the parties. Petitioner and respondent did not
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