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trial balances to prepare the Sley Corporations’ tax returns.
Brown was not assigned to do, and did not do, any verification of
the truth of the figures on the books and records kept by
Baybrook.
Baybrook was Brown’s primary contact person regarding the
Sley Corporations’ tax returns during the period February 1985
through March 1986; Brown occasionally spoke to petitioner about
the Sley Corporations’ tax returns. Brown had no discussions
regarding the Sley Corporations’ tax returns with either Betsy or
Ben before April 1986; Brown had never even met either of them.
In April 1987, Brown ended her employment with Grant
Thornton; in May 1987, petitioner and Betsy hired Brown to work
for the Sley Corporations. Brown prepared the Sley Corporations’
tax returns for 1987 and 1988. As part of her duties, Brown also
prepared tax returns for trusts of which Betsy or Ben were
beneficiaries.
In 1988 Betsy hired an independent accountant named Olshan,
primarily to help with investments. Brown began to discuss the
travel expenses and some other matters that she noted on the Sley
Corporations’ tax returns. As a result of a discussion between
Betsy, Brown, and Olshan, in early 1988 Betsy had the Sley
Corporations issue a Form 1099 for 1987 dividend income received
in the form of payment of travel expenses. Also, for 1988,
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