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officer of the company, oversaw all financial and administrative
functions. Each of the men, however, performed a variety of
duties within the organization. As stated by Joseph Deitsch, “in
our company, * * * everybody is involved in everything” and
“Everybody wears many hats.”
Flocktex Industries, Ltd.
In the early 1970’s, David Deitsch began, at the suggestion
of his rabbi, to investigate the possibility of opening a
business in Israel. FIL was then established in 1974 as an
Israeli corporation. The company is located in Kiryat Malachi,
Israel, and manufactures flocked fabrics principally for use in
the production of drapery and upholstery. Like DPC, FIL has at
all times been closely held by members of the Deitsch family.
Stock ownership during the years at issue is set forth below:
David Deitsch .0001 percent
Sara Deitsch .0001 percent
Mordecai Deitsch 20 percent
Joseph Deitsch 20 percent
Rachel Sandman 19.999 percent
B. Mayer Zeiler 20 percent
Jacob Pinson 20 percent
(Again, we note that the stipulated values total only 99.9992
percent.)
Financing for the startup of FIL was provided through the
Industrial Development Bank of Israel, Ltd., an Israeli
governmental organization. To obtain financing of this type, the
Deitsches were required to comply with conditions designed by
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