Robert D. Grossman, Jr. - Page 80

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          amount for which each payroll check should be written and later             
          told her when the amounts of the payroll checks changed.  See               
          infra Salaries and Dividends.  Baybrook was not told the reasons            
          for the changes.  When petitioner gave these instructions to                
          Baybrook, he did not indicate to her that he was passing on                 
          instructions from the Sley Corporations’ officers.  Baybrook also           
          prepared the Sley Corporations payroll tax returns; petitioner              
          signed them.  Petitioner signed Sley Corporations tax returns as            
          an “officer”; the “title” he used was “attorney”.                           
               Baybrook prepared summary financial statements of                      
          petitioner’s income based on the books she kept for the Sley                
          Corporations and for Grossman & Flask; Baybrook did not intend              
          that these summaries be all-inclusive, but she tried and intended           
          to include everything that occurred “inside the office”--that is,           
          the income from Grossman & Flask and from the Sley Corporations.            
          Baybrook was not asked by petitioner to prepare the summary                 
          financial statements; Baybrook prepared them as a courtesy to               
          Harvey J. Berger, hereinafter sometimes referred to as Berger,              
          the accountant who, from 1980 on, prepared the Sley Corporations’           
          tax returns and petitioner’s and Betsy’s joint tax returns.                 
          Baybrook gave the summary financial statements to petitioner so             
          that he could make sure that all items of income and deductions             
          were included.  Baybrook was never asked to prepare a schedule of           
          constructive dividends.                                                     






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