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Before 1986, Betsy had a general understanding of what
assets the Sley Corporations held, participated in general family
discussions about the Sley Corporations, and “just read up on
different things and the Wall Street Journal.” From 1980 through
about March 1986, Betsy did not go into the Sley Corporations’
office, review the monthly financial statements, or sign Sley
Corporations’ correspondence on a regular basis. From 1979
through early 1986, Betsy merely signed whatever petitioner asked
her to sign. Before 1986, Betsy did not have any involvement in
the preparation, review, or filing of the Sley Corporations’ tax
returns.
Ben lived in Texas during the years in issue and did not
take responsibility for, nor have any involvement in, the daily
operations of the Sley Corporations. Ben received copies of the
Sley Corporations’ tax returns, but he did not have any
involvement in the preparation and filing of those tax returns.
In 1984, Ben was involved in decision-making that led to the
liquidation of Twelfth and Sansom Corp. Also in 1984, Ben
proposed consideration of liquidating all the Sley Corporations.
Petitioner and Ben received a letter from Berger stating the pros
and cons of liquidation; Twelfth and Sansom Corp. was the only
one of the Sley Corporations that was liquidated.
In September of 1984, 1985, and 1986, Beatrice, Betsy, and
Ben met as the Markette board of directors, to authorize the
redemption of stock held by trusts of which Betsy and Ben were
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