- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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