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FINDINGS OF FACT
A. Petitioners
1. Generally
Petitioners were married and resided in Verona, New Jersey,
when they filed their petition.
Petitioner was born in 1914. He graduated from Dartmouth
University in 1936 with a degree in chemical engineering and
worked for chemical companies until 1951. As discussed in more
detail below in section B, petitioner owned and controlled the
Resyn Corporation (Resyn) during the years in issue.
Ruth Levitt was born in 1918. She graduated from high
school and secretarial school. Petitioners met in 1938 and
married in 1941. Ruth Levitt never worked outside the home.
Petitioners had four daughters, born in 1943, 1946, 1952, and
1956. Ruth Levitt took care of her ailing mother for a period of
time not specified in the record. She did not visit or know much
about her husband's business.
Petitioners bought land in South Orange, New Jersey, in
1948. Petitioners rented a dwelling until 1952 when they moved
into a home they built on their South Orange land. Ruth Levitt
had sole ownership of that home.
Petitioner did not have a personal checking account. Ruth
Levitt had checking and savings accounts from 1960 to 1970. She
used those accounts for the family finances. During the years
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