Robert D. Grossman, Jr. - Page 11

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          diamond brokers about selling the Sley Corporations’ diamonds.              
          We have accepted their testimony that this was not a vacation               
          trip.                                                                       
               We conclude, and we have found, that the expenditures for              
          the children on this New York trip were for personal purposes and           
          not for Sley Corporations business purpose.  Thus, Betsy received           
          a $520 constructive dividend from Markette.                                 
               We hold for respondent as to $520, and for petitioner as to            
          $470.34, on this issue.                                                     
               Summary--1983                                                          
               Our fraud issue holdings as to 1983 constructive dividends             
          are summarized in table 16.                                                 
                                   Table 16                                           
                             Respondent’s                                            
          1983 Trip            Contention on Brief          Court’s Holding           
          Miami                    $1,302.00                $1,302.00                 
          Hawaii                  5,326.51                 1,974.74                  
          Lake Tahoe              1,351.50                 1,033.50                  
          L.A. Olympics            1,359.55                 1,359.55                  
          New York                 990.34                     520.00                  
          Totals                   10,329.90                6,189.79                  
          (2) 1984                                                                    
               Miami                                                                  
               On February 21, 1984, Markette issued check No. 1946 to                
          Eastern Airlines, Inc., in the amount of $1,616.50.                         
               Apart from photocopies of the front and back of the check,             
          the only evidence in the record as to this item is the following            
          colloquy:                                                                   






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