Leo N. Levitt and Ruth G. Levitt - Page 33

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                    An analysis of the Chemical Traders' bank account                 
               and checks drawn on it shows that in 1966 it issued                    
               checks in the total amount of $462,921.00, of which                    
               $115,000.00 was written to cash.  Traced to Levitt's                   
               personal accounts with various stock brokerage firms                   
               was the sum of $84,941.00.  Additionally, a check drawn                
               to an unknown payee was deposited to Levitt's account                  
               at the Merchant's Bank of New York and another check                   
               also payable to an unknown payee was deposited to                      
               Levitt's account at Edwards & Hanley, a stock brokerage                
                    In 1967 Chemical Traders issued checks totalling                  
               $320,000.00.  Of this sum, a total of $106,500.00 was                  
               deposited into various personal accounts held by Levitt                
               with various stock brokerage firms while the                           
               disposition of an additional $128,500.00 is unknown.                   
               Given the total control Levitt had over this account                   
               and his total control of the Resyn operation, his                      
               failure to testify as to unidentified deposits and                     
               withdrawals on the account is significant.  * * *                      
          In re Resyn Corp., 81-2 USTC par. 9808, at 88,686-88,691 (Bankr.            
          D.N.J. 1981).                                                               
               The bankruptcy court entered a judgment against Resyn on               
          December 9, 1981.  The District Court for the District of New               
          Jersey entered opinions on November 22, 1982, August 19, 1986,              
          and December 31, 1986, on appeal from the bankruptcy court's                
          judgment.  The Court of Appeals for the Third Circuit issued two            
          opinions, Resyn Corp. v United States, 851 F.2d 660 (3d Cir.                
          1988), and In re Resyn Corp., 945 F.2d 1279 (3d Cir. 1991).  The            
          District Court entered its order on remand on July 9, 1992.                 
          There has been no appeal from that order.                                   
          L.   Sale of Resyn Corporation                                              
               Petitioner sold Resyn to Celanese Corp. in August 1977.  In            
          1981, Resyn had no assets, but was liable for obligations to                
          Celanese Corp. and to respondent.                                           

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