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AMERICAN VALMAR INTERNATIONAL LTD., INC. v. COMMISSIONER

Docket Nos. 11776-95, 11777-95, 16318-96, 16319-96.

76 T.C.M. 911 (1998)

T.C. Memo. 1998-419

American Valmar International Ltd., Inc., et al. v. Commissioner.

United States Tax Court.

Filed November 19, 1998.

Attorney(s) appearing for the Case

Ira B. Stechel, New York, N.Y., and Thomas J. Fleming, for the petitioners. Daniel O'Brien and Patrick E. Whelan, for the respondent.

MEMORANDUM FINDINGS OF FACT AND OPINION

HALPERN, Judge:

These cases have been consolidated for trial, briefing, and opinion. By separate notices of deficiency, respondent had determined deficiencies in, additions to, and penalties with respect to the Federal income taxes of petitioners Valeri Markovski (Markovski) and American Valmar International, Ltd., Inc. (American Valmar) as follows:

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