Leo N. Levitt and Ruth G. Levitt - Page 4

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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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