- 68 -                                         
               Berger prepared the Sley Corporations’ tax returns based on            
          the books and records of the Sley Corporations, primarily the               
          general ledger and the trial balances.19  Berger did not                    
          routinely verify the general ledger and the trial balances                  
          against supporting documents before preparing the corporate tax             
          returns; Berger’s firm was not retained to do any audit work on             
          behalf of the Sley Corporations.  Baybrook was Berger’s principal           
          contact at the Sley Corporations and the person who provided                
          Berger with information; petitioner was the secondary contact               
          person.  Berger did not have any business discussion with Betsy             
          about the Sley Corporations until late 1986.  Berger had access             
          to all of the Sley Corporations’ books and records that he asked            
          for.                                                                        
               Berger did not give Baybrook instructions about how to                 
          report transactions or how to define expenses for the Sley                  
          Corporations.                                                               
               Berger was aware that Beatrice, Betsy, and Ben were                    
          receiving six-figure salaries from the Sley Corporations; Berger            
          did not know how the salary structure was established, who                  
          established the salary structure, or what Beatrice, Betsy, and              
               19   A trial balance is a listing of all account balances.             
          It provides a means of testing whether total debits equal total             
          credits for all accounts.  Generally, trial balances are used to            
          prepare financial statements.  Skousen et al, Financial                     
          Accounting 62, 758 (4th ed. 1991).                                          
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