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them by Jaffe for their signature.
The lack of involvement by James and John in the tax affairs
of their corporation, and the degree to which James and John
relied on Jaffe to handle those affairs, is aptly demonstrated by
the following colloquies between counsel and John and then James:
PETITIONER’S COUNSEL: And why would you sign
these documents?
JOHN GIBBS: I just totally trusted Steve. I
would sign the papers, he’d put them down. I wouldn’t
look at them.
* * * * * * *
PETITIONER’S COUNSEL: Before July ‘98, did you
ever execute any tax document, returns, or financial
statements for Trans World at the direction of Jaffe?
JAMES GIBBS: Yes, I did.
PETITIONER’S COUNSEL: Would you review these
documents?
JAMES GIBBS: No. Basically, again, he would just
present them to me for my signature.
PETITIONER’S COUNSEL: Now why would you just
execute documents?
JAMES GIBBS: One, again, he was a friend. We
trusted him. And for the most part, I wouldn’t have
understood the documents that are given to me
pertaining to the taxes.
* * * * * * *
RESPONDENT’S COUNSEL: Did you ask Steve Jaffe
what this document [the designation of place of trial]
was?
JAMES GIBBS: No, I did not.
RESPONDENT’S COUNSEL: You didn’t ask him what it
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