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capital gain of $999,338 from the liquidation of Welev stock,
which she reported that she acquired in 1964.
3. Petitioners' Income Tax Returns
Petitioners filed joint income tax returns for 1963 to 1970.
Harry Levenson (Levenson) prepared petitioners' income tax
returns for 1964, 1965, and 1966. He was an accountant. His
office was at 152 Clinton Avenue in Newark, New Jersey. He later
moved to 441 Springfield Avenue in Newark. Levenson previously
served as a revenue agent for the Internal Revenue Service (IRS).
Levenson's wife was Ruth Levitt's cousin.
Howard Goldstein (Goldstein) prepared petitioners' returns
for 1967, 1968, 1969, and 1970. Goldstein was an accountant. He
practiced at the certified public accounting firm of I. George
Goldstein & Co. (Goldstein & Co.). I. George Goldstein was
Goldstein's father. Petitioner gave Levenson and Goldstein
information to prepare his returns, including Forms 1099, Forms
W-2, and brokerage account statements.
Petitioners reported wages from Resyn of $35,000 per year
for 1964 and 1965, $50,000 for 1966, 1967, 1968, and 1969, and
$47,960 for 1970. They reported withholding on those wages of
$10,000 per year in 1964 and 1965, $13,282.97 in 1966, $12,876 in
1967, $14,000 in 1968, $16,000 in 1969, and $11,887.85 in 1970.
Petitioners did not report as income any of the amounts Resyn
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