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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulation of facts is incorporated in this opinion by this
reference.
A. Background
The Zhadanovs were married in 1957 and remained married
throughout the years at issue. The Zhadanovs were born in Kiev,
Ukraine, and immigrated to the United States in 1973. Before
they emigrated, both Mr. and Mrs. Zhadanov earned a degree in
mechanical engineering in the former Soviet Union. The
Zhadanovs’ legal residence was in Brooklyn, New York, when they
filed their petitions in this case.
Mr. Zhadanov was president and sole shareholder of Vortex
Products Corp. (Vortex) during the years at issue. Vortex had
its principal place of business in Brooklyn, New York, when it
filed its petition in this case.
In 1981, Vortex was incorporated in New Jersey to engineer,
develop, and manufacture plastic products. Since its
incorporation, Vortex has derived its income from the manufacture
and sale of various brush products, safety syringe holders, and
custom-molded products for which Mr. Zhadanov held patents. For
5(...continued)
relief from joint and several liability for any income tax
deficiency for 1993 under sec. 6015. However, Mrs. Zhadanov
filed a separate Federal income tax return for 1993, and,
therefore, sec. 6015 does not apply to 1993.
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