Under similar facts, this Court has rejected the same contentions. See W. O. Menger, 17 B.T.A. 998; Rite-Way Products, Inc., 12 T.C. 475, 479; Helen Epstein, 17 T.C. 1034; Anne Gatto, 20 T.C. 830; and James M. Denton, 21 T.C. 295. See also Lucas v. Hunt, 45 F.2d 781; United States v. City of New York, 134 F.Supp. 374; and Estate of Umberto Dardi v. United States, 252 F.2d 670.
The question of who has authority to act on behalf of a dissolved corporation is controlled by State law. United States v. Krueger, 121 F.2d 842 (3d Cir. 1941); Associates Investment Co., 59 T.C. 441, 442 (1972); Helen Epstein, 17 T.C. 1034, 1036 (1951). Under New Jersey law prior to January 1, 1969, the directors of a dissolved corporation became trustees thereof and effectuated dissolution in that capacity.