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including directions with respect to paying bills, exclusively
from petitioner.
Petitioner brought the American Express invoices to Baybrook
and told her which of the Sley Corporations was to pay for the
charges on a particular invoice. After Baybrook prepared a check
as payment, she attached the check to the invoice and returned it
to petitioner for his final review. Petitioner closely reviewed
each check against each invoice, as well as each transaction on
each invoice. Petitioner signed most of the Markette checks to
pay for the charges on the American Express invoices; Betsy
signed checks when petitioner asked her to do so. In verifying
the charges on the American Express invoices, petitioner checked
with Betsy, on at least some occasions, to determine whether
Betsy had made a particular charge. Petitioner never told
Baybrook that a travel expense on an American Express invoice was
a personal item, and thus was not to be paid by the Sley
Corporations.
(3) Petitioner’s Knowledge of Berger’s Limited Role
Petitioner brought Berger into the picture, initially to
prepare the Sley Corporations’ 1980 tax returns. Berger
continued preparing the Sley Corporations’ tax returns,
petitioner’s and Betsy’s tax returns, and the Sley Corporations’
compilation financial statements; he also calculated the amounts
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