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Q The Olympics that year were late July and early
August of 1984?
A Yes.
Q Would you have flown United Airlines to the
Olympics?
A I don’t remember.
Q So you don’t know whether this check went to the
Olympics or not?
A The check didn’t go to the Olympics. The check is
written out to United Airlines.
Q My question was very poorly worded. You don’t have
any idea whether this check related to the Olympics trip?
A I can’t say for sure.
Q Do you remember any business trips you took on
behalf of Markette Corporation at around the time of the
Olympics?
A I can’t say for sure.
We cannot determine from the foregoing whether or not Betsy
received a constructive dividend on account of that payment.
Respondent has failed to carry the burden of proving that
constructive dividend by clear and convincing evidence.
We hold for petitioner on this issue.
Orlando
On September 27, 1984, petitioner, Betsy, and the children
flew to Orlando, Florida; they returned on September 30, 1984.
See Findings Check No. 2008--Orlando, supra. Betsy testified
that they went to Orlando to meet Ben at Walt Disney World. She
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