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a particular vacation trip, then Betsy told petitioner of the
trip.
Secondly, petitioner knew that expenses of these vacation
trips were charged to Markette, because he, himself, charged many
of those expenses on his Markette American Express credit card.
In 1983, petitioner charged on his American Express credit card
the airfare to Lake Tahoe and all the expenses associated with
the Hawaii trip. On the 1983 New York City trip, all the charges
were on Betsy’s Markette American Express credit card, but
petitioner signed the credit slips for the hotel, etc., expenses.
In 1985, petitioner charged most of the expense of the Acapulco
trip, the expense associated with the trip to Stamford, and all
but the airline ticket portion of the expenses associated with
the trip to Canada. In 1986, petitioner charged part of the
expenses associated with the trips to Miami, dinner for
petitioner and Betsy at the Shoreham Hotel, the charges from
Lenny’s Restaurant and Vista International Hilton, and part of
the expenses associated with the second trip to Key West.
(2) Petitioner’s Knowledge of Payments
Petitioner knew that Markette paid for the charges on the
Markette American Express credit cards, because he directed
Baybrook to make those payments. Petitioner supervised Baybrook
in her duties for the Sley Corporations, and she took directions,
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