American Valmar International Ltd., Inc. & Valeri Markovski v. Commissioner of Internal Revenue
Court of Appeals for the Second Circuit
1Opinion of the Court
WINTER, Circuit Judge:
American Valmar International Ltd., Inc. (“Valmar”) and Valeri Markovski (“Markovski”) appeal from a decision of Tax Court Judge Halpern finding deficiencies and imposing accuracy-related and delinquency penalties for the taxable years 1991, 1992, and 1993. See American Valmar Int’l Ltd. v. Commissioner, 76 T.C.M. (CCH) 911 (1998) (unpublished memorandum opinion).
On appeal, Valmar contends that the Tax Court erred in holding that: (i) customer funds deposited with Valmar were taxable income to Valmar; (ii) Valmar’s taxable income could not be reduced by various…
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