- 124 - 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 amountsPage: Previous 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 129 130 131 132 133 Next
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