Howard H. Thompson, Jr. - Page 19

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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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