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findings of fact in the instant case. Chatham Corp. v.
Commissioner, 48 T.C. at 147; Soros Associates Intl., Inc. v.
Commissioner, supra.
Petitioner is engaged primarily in clothing manufacturing
and retailing.
During 1932, the predecessor Zeeman clothing company was
founded by Harold Zeeman, Sr., in Allentown, Pennsylvania, as a
manufacturer and wholesaler of men's clothing. At that time, the
manufacturing facilities consisted of only a cutting room on the
fourth floor of a building. This cut work was sent to
contractors in Philadelphia, Pennsylvania, for assembly and
thereafter sold in retail stores. When retailers could not pay
their bills, Harold Zeeman, Sr., and his brothers Edward and
Jessie began selling directly to the public from their cutting
room. As the business thrived, the company opened a retail store
on the ground floor. Subsequently, similar factory stores were
opened in Harrisburg, Pennsylvania, and Richmond, Virginia.
During the 1940's, wholesale stores were opened in California.
After 1949, Harold Zeeman, Sr., and his son, Harold Zeeman,
Jr., (Mr. Zeeman) started a wholesale sport coat business. A
sales force was hired, a sales office was opened in New York
City, and a substantial business was developed. During 1964,
when labor problems arose in Allentown, Mr. Zeeman moved
petitioner's entire manufacturing operation to Gainesville,
Georgia. A retail store was soon opened at the factory site.
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