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Robinson’s American Express account (Mr. Robinson’s American
Express account) by having Mr. Robinson authorize American
Express to issue a credit card in petitioner’s name with respect
to Mr. Robinson’s American Express account. In return for Mr.
Robinson’s authorizing petitioner to have a credit card issued
with respect to Mr. Robinson’s American Express account, peti-
tioner agreed that Mr. Robinson was to receive and retain all the
points from American Express that accrued for each dollar of
charges that petitioner incurred using that card. In January
1994, Mr. Robinson agreed to petitioner’s arrangement with Mr.
Robinson, and American Express issued a credit card to petitioner
with respect to Mr. Robinson’s American Express account (peti-
tioner’s American Express card issued on Mr. Robinson’s American
Express account). As part of petitioner’s arrangement with Mr.
Robinson, petitioner submitted to Mr. Robinson payments for
charges that petitioner incurred on petitioner’s American Express
card issued on Mr. Robinson’s American Express account.
During the time petitioner’s arrangement with Mr. Robinson
was in effect, American Express issued bills to Mr. Robinson for
all charges made on Mr. Robinson’s American Express account,
including the charges that petitioner made on petitioner’s
American Express card issued on Mr. Robinson’s American Express
account. American Express held Mr. Robinson accountable for any
charges that petitioner made on petitioner’s American Express
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