American Valmar International Ltd., Inc. & Valeri Markovski v. Commissioner of Internal Revenue

How courts have described this case

Verbatim parenthetical descriptions written by other courts when citing this decision. Ranked by citation-network relevance.

• noting that this Court owes “particularly strong deference” to Tax Court’s “determination of witnesses’ credibility” (internal quotation marks omitted)
• finding customer deposits held by international broker not income because the broker had an obligation to use the deposits for the customers’ benefit or to repay them
• ‘‘We must uphold the Tax Court’s factual findings unless they are clearly erroneous . . . . Customer deposits over which the recipient does not have ‘complete dominion’ are not taxable as income upon their receipt.’’ (Citations omitted; footnote omitted.)

Source: CourtListener parenthetical corpus (CC0).