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testified that Ben had “some kind of new computer system that he
was working with futures in the market.”
We are satisfied that, when parents take their three
children (then aged 14, 11, and 8) to Walt Disney World on a 3-
day trip, the trip is for personal purposes unless something
appears in the record to lead us to a different conclusion. The
only suggestion in the record as to a Sley Corporations business
purpose is Betsy’s reference to Ben’s “computer system”. There
is no evidence of any discussions at Walt Disney World about the
Sley Corporations possible use of whatever Ben had found or
developed, nor is there anything in the record indicating why it
made business sense to travel from Washington, D.C., to Orlando
(and, in Ben’s case, from Corpus Christi to Orlando) for any such
discussions. See George R. Holswade, M.D., P.C. v. Commissioner,
82 T.C. at 701-702.
As we have found, Markette’s American Express October
invoice showed an $860 credit on account of an item paid for on
the August invoice and carried over to the September invoice.
The September invoice was paid. The October invoice also showed
the $780 charge for the Orlando tickets. This left a credit
balance of $80 to be carried over to the next invoice. Thus the
Orlando tickets were indirectly paid for by Markette’s check No.
2008.
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