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Daily Operations: 1980 Through March 1986
In the fall of 1980, after Hicks resigned, the business
offices of the Sley Corporations were moved from Philadelphia to
Washington, D.C., into space sublet from and adjacent to Grossman
& Flask’s office. Later, when the Grossman & Flask office was
moved, the Sley Corporations’ office was simultaneously moved, so
that the Sley Corporations’ office remained in sublet office
space of Grossman & Flask throughout the years in issue. When
the Sley Corporations’ offices moved to Washington, D.C.,
petitioner took control of the daily operations of the Sley
Corporations. Betsy did not give petitioner directions as to how
to run the daily operation of the Sley Corporations.
Tanja Baybrook, hereinafter sometimes referred to as
Baybrook, was the bookkeeper for the Sley Corporations from
September 1980 to March 1986. She has a B.S. degree in
accounting from Northeastern University. Petitioner interviewed
and hired Baybrook for this bookkeeping position. Petitioner
explained to Baybrook her duties with the Sley Corporations, and
told her that she was to report to him in connection with that
work. Petitioner supervised Baybrook in carrying out her duties
for the Sley Corporations. During Baybrook’s interview,
petitioner told her that he was administering the Sley
Corporations. Baybrook saw Betsy and Ben in the Sley
Corporations’ office on a few occasions, but not on a regular
basis; she saw Beatrice there only once. Baybrook never received
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