- 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 to
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