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the beneficiaries. From 1983 to 1986, these three meetings were
the only meetings held of the Sley Corporations’ directors. The
minutes prepared for these three meetings were the only minutes
prepared for the Sley Corporations for about 1982 through 1989.
During the period 1980 through 1986, petitioner and his law
firm performed legal services for the Sley Corporations. When
such services were performed, Grossman & Flask billed the client
for fees.
Daily Operations: After March 1986
Matters between petitioner and Betsy were deteriorating.
Petitioner and Betsy separated permanently in September 1986.
When Baybrook left the Sley Corporations in March 1986,
Betsy began to become more involved with the operation of the
Sley Corporations. Betsy began signing checks and tax returns;
she interviewed and hired a bookkeeper in July 1986, Bridgette
Coupeon, and a replacement for Bridgette Coupeon in September
1986, Evelyn Wilson, hereinafter sometimes referred to as Wilson.
Maggie-Jo Brown, hereinafter sometimes referred to as Brown,
is an accountant who originally was employed by the accounting
firm of Grant Thornton under Berger’s supervision. The first
week after Brown started at Grant Thornton, in February 1985,
Berger assigned her to prepare the 1984 tax returns and
compilation financial statements for the Sley Corporations.
(For a description of the compilation financial statements, see
Financial Statements, etc., infra.) After Baybrook left the Sley
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