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through July 1998, Coleman devoted relatively little time to the
Trans World Travel account.
James and John relied on CJ&J, and particularly on Jaffe, to
handle all of petitioner’s accounting and tax matters, and James
and John had confidence that CJ&J, and particularly Jaffe, would
do so in a professional, competent, and timely manner.
James and John placed a very high level of trust in Jaffe,
and they also regarded him as their friend. James and John gave
Jaffe full and unfettered access to petitioner’s books and
records, and they authorized him to contact directly the vice
president of the financial institution with which petitioner
banked.
Because of their trust in, and reliance on, Jaffe, neither
James nor John paid close attention to petitioner’s tax matters.
Rather, James and John adopted a hands-off approach, essentially
delegating responsibility for petitioner’s tax matters to Jaffe.
Both James and John frequently signed, without scrutiny or
inquiry, tax-related documents that were presented to them by
Jaffe for their signature.
C. Petitioner’s Office Procedures Related to Mail
Mail addressed to petitioner at its Highland Park office was
received and sorted by petitioner’s receptionists. Mail routed
to John was opened and read by him. Tax-related mail was routed
to James’ office, where it was placed in a box reserved for
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