Leo N. Levitt and Ruth G. Levitt - Page 13

                                       - 13 -                                         
                         Mar. 17, 1969       13,000                                   
                         Apr. 18, 1969       5,500                                    
                         May  21, 1969       12,000                                   
                         Jun. 20, 1969       8,000                                    
                         Jul. 25, 1969       13,000                                   
                         Sep. 19, 1969       5,000                                    
                         Sep. 30, 1969       15,000                                   
                         Oct.  8, 1969       10,000                                   
                         Oct. 23, 1969       5,000                                    
                         Oct. 31, 1969       5,000                                    
                         Nov. 14, 1969       6,000                                    
                         Nov. 29, 1969       5,000                                    
                         Dec. 22, 1969       5,000                                    
               The checks were negotiated in the year written.                        
          D.   Chemical Traders                                                       
               1.   Petitioner's Formation and Use of Chemical Traders                
               On May 31, 1955, petitioner and his brother, Jesse Levitt,             
          registered the trade name Chemical Traders with the State of New            
          Jersey.  The trade name certificate stated that Chemical Traders            
          would do business at 128 Clinton Avenue, Newark, New Jersey.                
          Petitioner opened a Chemical Traders bank account on November 20,           
          1959.  Chemical Traders had a checking account at the National              
          State Bank, Hillside, New Jersey, from 1963 to 1970.  Petitioner            
          signed the signature card for the account and personally                    
          conducted Chemical Traders' transactions at the National State              
          Bank.  Chemical Traders monthly bank statements did not have a              
          mailing address.  Petitioner picked up the Chemical Traders'                
          monthly bank statements and canceled checks.  Philbin, Levenson,            
          and Goldstein did not know about Chemical Traders or the Chemical           
          Traders bank account at the National State Bank during the years            
          in issue.                                                                   




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