Leo N. Levitt and Ruth G. Levitt - Page 11

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          the Resyn bankruptcy for $200,000 after 1970.  She later received           
          37-1/2 cents per dollar of claim.  Petitioner had not repaid                
          Resyn by the time of the bankruptcy trial in 1981.                          
               Resyn did not report paying any dividends from 1963 to 1970.           
          C.   Polymer Chemicals                                                      
               1.   Formation of Polymer Chemicals                                    
               Petitioner suggested that he and Levenson form a partnership           
          called Polymer Chemicals (Polymer).  On September 17, 1954,                 
          Levenson registered the trade name Polymer Chemicals with the               
          State of New Jersey under his name alone.  The trade name                   
          certificate stated that Polymer's address was 152 Clinton Avenue,           
          Newark, New Jersey, which was Levenson's office.  Polymer  never            
          did business at that address.  Polymer had a checking account at            
          the National State Bank, Hillside, New Jersey, from 1963 to 1970.           
          Although Levenson was authorized to sign checks on the Polymer              
          account, petitioner directed him to sign and endorse blank                  
          Polymer checks.  Levenson never saw the proceeds from these                 
               The monthly bank statements did not include a mailing                  
          address for Polymer.  Petitioner went to the bank to get                    
          Polymer's bank statements and canceled checks.  Polymer did not             
          file Federal income tax returns.                                            
               2.   Polymer Transactions                                              
               Unlike other Resyn transactions the Polymer purchase                   
          invoices did not include any bills of lading.  Resyn's checks to            

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