opinion: LEHN & FINK PRODUCTS CORPORATION v. COMMISSIONER OF INTERNAL REVENUE.
  Nos. 9335, 9336.
  Circuit Court of Appeals, Third Circuit.
  Argued Dec. 2, 1947.
  Decided Jan. 6, 1948.
  Montgomery B. Angelí, of New York City (Lucius A. Buck, D. Nelson Adams and Chauncey Belknap, all of New York City, on the brief), for petitioner.
  I. Henry Kutz, of Washington, D.C. (Theron Lamar Caudle, Asst.Atty.Gen., and Helen R. Carloss, Sp.Asst. to the Atty. Gen., on the brief), for respondent.
  Before BIGGS, MARIS and KALODNER, Circuit Judges.
  PER CURIAM.
  The question presented by the appeals at bar is whether the Tax Court’s findings of fair market value of certain property, including trade-marks, trade names, secret processes, formulas and good will of A. S. Hinds Company possessed substantial basis in the evidence, or were arbitrary or capricious. See 7 T.C.287. Examination of the record and of the briefs filed by the parties and consideration of the oral argument convince us that the conclusions of the Tax Court do find substantial ground in the evidence. As we stated in Cochran v. Commissioner, 3 Cir., 163 F.2d 153, 155, the values of properties “are purely questions of fact”. We went on to say that if there was any evidentiary basis for the Tax Court’s finding we could not substitute our own evaluation for that of the Tax Court. The appeal at bar is ruled by such cases as Dobson v. Commissioner, 320 U.S. 489, 64 S.Ct. 239, 88 L.Ed. 248, and Commissioner v. Scottish American Co., 323 U.S. 119, 65 S.Ct. 169, 89 L.Ed. 113.
  Accordingly the decisions of the Tax Court will be affirmed.
instruction: What follows is an opinion from a United States Court of Appeals.
  Intervenors who participated as parties at the courts of appeals should be counted as either appellants or respondents when it can be determined whose position they supported. For example, if there were two plaintiffs who lost in district court, appealed, and were joined by four intervenors who also asked the court of appeals to reverse the district court, the number of appellants should be coded as six.
  When coding the detailed nature of participants, use your personal knowledge about the participants, if you are completely confident of the accuracy of your knowledge, even if the specific information is not in the opinion. For example, if "IBM" is listed as the appellant it could be classified as "clearly national or international in scope" even if the opinion did not indicate the scope of the business. 
  
  Your task concerns the first listed appellant. The nature of this litigant falls into the category "private business (including criminal enterprises)", specifically "unclear". Your task is to determine what subcategory of business best describes this litigant.
choices: auto industry chemical industry drug industry food industry oil & gas industry clothing & textile industry electronic industry alcohol and tobacco industry other unclear