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Miami to meet their grandmother, Beatrice. Petitioner does not
even bother to suggest a possible Sley Corporations business
purpose, and we have found that the Miami trip was for a personal
family vacation purpose. Betsy testified that “The reason that
they [the children] went to Miami was because of the babysitter
situation.”
We are satisfied that respondent has shown by clear and
convincing evidence that the children’s Miami trip was for
personal purposes and not for Sley Corporations business, and
that Markette’s payment of the cost of the airline tickets
constituted constructive dividend income to Betsy, reportable on
petitioner’s and Betsy’s 1985 joint tax return.
We hold for respondent on this issue.
Miami
On February 4, 1985, Markette issued check No. 2043 to
Eastern Airlines, Inc., in the amount of $1,192. On February 26,
1985, Markette issued check No. 2051 to Eastern Airlines, Inc.,
in the amount of $974.
Apart from photocopies of the fronts and backs of the
checks, totaling $2,166, the only evidence in the record as to
this item is the following colloquy:
Q [McDougal] If you’ll turn, please, to page 20, we
will skip the Marriott invoice at the top because it does
not appear to have been charged to the corporation.
Mrs. Grossman, would you look at AP, the checks, the
‘85 section, check number 2043, which is about the fifth
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