Sam and Anna Zhadanov, et al. - Page 5




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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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