Robert D. Grossman, Jr. - Page 17

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               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 to            





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