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FabuGlass reported $0 sales or costs of goods sold in 1989.
It rented the Conway premises to an unidentified tenant for
$66,000 in 1989.
FabuGlass purchased $922,370 of securities for investment in
1989. In 1989, FabuGlass also had receivables of $1,015, liquid
assets of $899, and owned a building with a book value of
$248,681 less accumulated depreciation of $125,228.
In 1990-95, FabuGlass derived income from renting real
property and trading stocks and securities. Petitioner operated
FabuGlass as a business consulting company in 1996 and 1997.
FabuGlass was an Arkansas corporation that had filed all
required reports and paid all required fees and taxes as of the
date of trial. It had not liquidated its assets or filed for
bankruptcy protection as of the date of trial.
B. AmRuss, Ltd.
In 1992 or 1993, Raymond Sawyer (Sawyer), petitioners’
accountant, and petitioner attempted to do business in Russia
through AmRuss, Ltd. (AmRuss). FabuGlass was not involved in
petitioner’s efforts to do business in Russia.
In 1991-94, Charles Layman (Layman) owned a company called
Murphy Body Co. Murphy Body Co., AmRuss, and a Russian entity
named Association Vnedrenie agreed to do business converting
vehicles into refrigerated or armored trucks, ambulances, and
other specially used vehicles in 1991-94. The contract between
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