Appeal of West 28th Street Corp.

*149OPINION.

The proofs amply sustain the petitioner’s contention that the corporations were affiliated during the year in question. The evidence clearly establishes the fact that the actual ownership of all stock in both corporations was in'George A. Potterton and his brother, John H. Potterton, or his estate, and the relative proportion of their ownership was substantially the same in each company.

Order of redetermination will be entered on 15 days' notice, under Bule 50.