Zarkin v. United States
United States Tax Court
Charles Zarkin owned and controlled a corporation which substantially financed the partnership petitioner. One individual managed both business entities. Charles Zarkin's copartners in the partnership were related to him by blood or marriage, and were employees of his corporation.
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Charles Zarkin owned and controlled a corporation which substantially financed the partnership petitioner. One individual managed both business entities. Charles Zarkin's copartners in the partnership were related to him by blood or marriage, and were employees of his corporation. Held, the partnership petitioner and the corporation were under common control within the meaning of section 403 (c) (6) of the Renegotiation Act of 1943, and the partnership realized excessive profits in its fiscal years 1944 and 1945, of $ 10,000 and $ 35,000, respectively.
1Opinion of the Court
OPINION.
Train, Judge:
Pursuant to tbe Renegotiation Act of 1943, tbe respondent unilaterally determined that tbe petitioner Zenith Export & Processing Co. realized excessive profits in its fiscal years ended August 31, 1944 and 1945, in the amounts of $10,000 and $35,000, respectively.
Tbe only issue to be decided is whether the petitioner was under the control of, or controlling, or under common control with Zar-ldn Machine Co., Inc., within the meaning of section 403 (c) (6) of the Renegotiation Act of 1943.1
All the facts have been stipulated and are hereby found as stipulated.
Zenith Export &…
2Cases cited7 opinions
- Lowell Wool By-Products Co. v. War Contracts Price Adjustment BoardCourt of Appeals for the D.C. Circuit · 1951
- Warner v. War Contracts Price Adjustment BoardUnited States Tax Court · 1950
- Hoffman v. United StatesUnited States Tax Court · 1954
- Pechtel v. United StatesUnited States Tax Court · 1952
- Southland Steel Co. v. War Contracts Price Adjustment BoardUnited States Tax Court · 1949
2 more not listed; retrieve them via the Exa API.
3Cited by1 opinion
- Zarkin v. United StatesUnited States Tax Court · 1958