Leo N. Levitt and Ruth G. Levitt - Page 7

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          paid for their benefit.  See section B-3, below.  Petitioners               
          reported $27,300 in miscellaneous income for 1970.                          
          B.   Resyn Corporation                                                      
               1.   Formation of Resyn Corporation                                    
               Petitioner and about 11 other people formed a chemical                 
          company called Resyn in 1951.  Resyn was incorporated in 1953.              
          Its principal offices were in Linden, New Jersey.  Petitioner               
          bought the stock of the other Resyn shareholders around 1956 for            
          the amount of their original investment in the company.                     
          Petitioner controlled Resyn's operations during the years in                
          issue.                                                                      
               2.   Resyn Corporation's Operations                                    
               Resyn bought, manufactured, and sold resins and other                  
          chemicals and oils used to manufacture paint.  In the late                  
          1950's, Resyn began to produce a chemical resin used by the Ford            
          Motor Co. in automobile paint.  Resyn made Mobil 1 for the Mobil            
          Oil Co.  Resyn was the fourth company in the United States to               
          manufacture epoxy.                                                          
               Atlas Paint and Varnish Co. (Atlas) was one of Resyn's                 
          larger customers from 1963 to 1970.  Meyer and Harry Tepperman              
          (the Tepperman brothers) owned Atlas.  Atlas manufactured paint.            
          Atlas bought large amounts of alkyds from Resyn to make paint.              









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