ZARKIN v. UNITED STATES

Docket No. 815-R.

29 T.C. 642 (1958)

CHARLES ZARKIN, LEWIS PUDNOS, SAMUEL FEIERTAG, BORIS WENGEL, AND LEO SIEGEL, CO-PARTNERS, DOING BUSINESS AS ZENITH EXPORT & PROCESSING CO., 332 E. 28TH STREET, NEW YORK, NEW YORK, PETITIONERS, v. UNITED STATES OF AMERICA, RESPONDENT.

United States Tax Court.

Filed January 13, 1958.


Attorney(s) appearing for the Case

Robert R. Daly, Esq., for the petitioners.

David V. Seaman, Esq., for the respondent.


OPINION.

TRAIN, Judge:

Pursuant to the Renegotiation Act of 1943, the respondent unilaterally determined that the petitioner Zenith Export & Processing Co. realized excessive profits in its fiscal years ended August 31, 1944 and 1945, in the amounts of $10,000 and $35,000, respectively.

The only issue to be decided is whether the petitioner was under the control of, or controlling, or under common control with Zarkin Machine Co., Inc....

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