Leo N. Levitt and Ruth G. Levitt - Page 18

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               In December 1970, petitioner filed a Statement of Affairs              
          with the bankruptcy court on behalf of Resyn, in which he                   
          answered certain questions.  Question 7 was as follows:                     

                    Bank accounts and safe deposit boxes                              
                         a.   What bank accounts have you maintained,                 
               alone or together with any other person and in your                    
               name or any other name, within the two years                           
               immediately preceding the filing of the original                       
               petition herein?                                                       
                    (Give the name and address of each bank, the name                 
               in which the deposit was maintained and the name of                    
               every person authorized to make withdrawals from such                  
          Petitioner answered question 7, but did not mention the Chemical            
          Traders or Polymer accounts.                                                
               The Commissioner filed a proof of claim on January 5, 1971,            
          and several amended proofs of claim between January 27, 1971, and           
          September 19, 1976.  The Commissioner filed a final amended claim           
          of $2,376,726.43 for unpaid corporate income taxes, interest, and           
          penalties for 1963 to 1970.                                                 
          F.   Respondent's Investigation of Petitioner and Resyn                     
               1.   Administrative Investigation                                      
               Respondent began a joint criminal and civil administrative             
          investigation of petitioner and Resyn in December 1970.  An                 
          administrative investigation is an investigation that is                    
          conducted solely by respondent's agents.  It is not conducted               
          before a grand jury.  A special agent and cooperating revenue               
          agents were assigned to the investigation.                                  

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