Robert D. Grossman, Jr. - Page 83

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          however, petitioner did speak to Ben before he moved funds out of           
          the National Permanent Bank of Washington in February 1986.                 
               In January 1981, petitioner became the named fiduciary for             
          the Markette Corporation Comprehensive Health Plan, which was               
          created at that time.  Petitioner was the administrator and one             
          of the trustees of the Parkette Corporation Profit Sharing Plan             
          and also of the Parkette Corporation Pension Plan.  Both of these           
          plans were established “as of” December 31, 1980, and both plans            
          covered employees of all the Sley Corporations.  In 1984,                   
          petitioner handled the sale of real estate that belonged to one             
          of the Sley Corporations.                                                   
               From 1980 to about March 1986, Betsy did not take an active            
          interest in the Sley Corporations, nor did she have a working               
          knowledge of the Sley Corporations’ operations.  During the years           
          in issue until March 1986, Betsy entrusted the entire operations            
          of the Sley Corporations to petitioner so that she could stay at            
          home to take care of her children; Betsy also was very involved             
          in civic activities.  During the years in issue until 1986, Betsy           
          and petitioner had, in Betsy’s words, an “old-fashioned                     
          relationship” where she took care of the children and the                   
          household, and petitioner took care of business matters, those              
          being his law practice and the daily operations of the Sley                 
          Corporations.  However, see our findings as to petitioner’s and             
          Betsy’s joint checking account, under Background, supra.                    






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