Leo N. Levitt and Ruth G. Levitt - Page 23

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          G.   Third Party Information                                                
               Respondent's agents suspected that Resyn had made payments             
          to fictitious entities.  Based on that theory, Cronin, Dorgeval,            
          and O'Byrne issued 48 administrative summonses from November 3,             
          1971, to September 26, 1972.  They issued administrative                    
          summonses to third parties including banks, businesses that                 
          bought and sold Resyn products, and Goldstein, who prepared                 
          petitioners' tax returns.  In the summons, they asked for bank              
          records, canceled checks, invoices, and other business records              
          pertaining to Resyn, Chemical Traders, Polymer, and petitioners.            
               Respondent's agents discovered the Chemical Traders account            
          between July 1971 and December 1972.                                        
               Respondent's agents could not reconstruct all of Resyn's               
          transactions because most of Resyn's business records for the               
          years in issue were missing.  Respondent's agents had only                  
          Resyn's general ledger and journal for 1969, purchase journals              
          for 1968 and 1969, and canceled checks for 1967, 1968, and 1969.            
          H.   Meetings With FBI Agents and Strike Force Attorney                     
               Rubenstein was an IRS employee who was the IRS liaison with            
          other strike force law enforcement agencies.  He also reviewed              
          strike force reports from other agencies for possible Internal              
          Revenue Code violations.  Cronin told the FBI that he suspected             
          that petitioner and Resyn might have violated bankruptcy laws.              
          Rubenstein arranged for Cronin to meet with two FBI agents from             
          the Newark Bankruptcy Fraud Squad.  The FBI did not investigate             

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