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3. Resyn's Payments for Petitioners' Personal Benefit
Resyn paid for many of petitioners' personal expenses and
personal stock investments.1 He had Resyn pay Ruth Levitt a
weekly allowance of about $350. Ruth Levitt received Resyn
checks paid to cash totaling $25,737 in 1967, $24,930 in 1968,
and $25,761 in 1969. She used those funds to pay household
expenses. Petitioner had Resyn pay the mortgage on their home.
Resyn paid $3,477.42 for 1967, $4,463.67 for 1968, and $4,081.35
for 1969 for the mortgage on petitioners' home.
Petitioner had Resyn pay for many of Ruth Levitt's shopping
expenses. In 1967, 1968, and 1969, Resyn also paid for Ruth
Levitt's purchases at Bloomingdale's, Saks Fifth Avenue, Fellers,
Lord & Taylor, and many other stores.
Resyn paid Evelyn Mejia, a nurse for petitioners' children,
and William Morrison, a handyman and chauffeur at petitioners'
home. Resyn paid landscaping and gardening expenses at
petitioners' home. Resyn paid petitioners' children's expenses
to attend Prospect Hill Country Day School, Newark Academy, and
Kenwood Camp for Girls from 1967 to 1969. From 1967 to 1969,
Resyn paid Berkeley School and MacBrian Educational Consultants,
Inc. Petitioners deducted $500 for 1967 and $100 for 1968 on
their income tax returns for charitable gifts to Camp Deal for
1 Resyn business records are missing except for parts of
1967, 1968, and 1969. There is no evidence that Resyn's
arrangements to pay petitioners' expenses were different from
1963 to 1966, or in 1970.
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