- 106 - We are satisfied, and we have found, that respondent has shown by clear and convincing evidence that the Orlando trip was for personal pleasure and not for Sley Corporations business. We conclude that Markette’s payment of the cost of the airline tickets constituted constructive dividend income to Betsy, reportable on petitioner’s and Betsy’s 1984 joint tax return. We hold for respondent on this issue. Summary--1984 Our fraud issue holdings as to 1984 constructive dividends are summarized in table 17. Table 17 Respondent’s 1984 Trip Contention on Brief Court’s Holding Miami $1,616.50 -- Miami 716.00 -- L.A. Olympics 2,057.00 -- Orlando 780.00 $780 Totals 5,169.50 780 (3) 1985 Miami Markette paid $397 for airfare to Miami for the children that Betsy charged on her Markette American Express credit card. Our Findings of Fact (Check No. 2036--Miami--Children, supra) detail the arrangements that led to the children flying from New York to Miami on December 26, 1984. It is clear that the children were on vacation in New York and traveled from there toPage: Previous 96 97 98 99 100 101 102 103 104 105 106 107 108 109 110 111 112 113 114 115 Next
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