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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.
Acapulco
Markette paid $3,682.21 on account of an April 1985 trip by
petitioner, Betsy, and the children to Acapulco. See Findings
Check Nos. 2084, and 2092--Acapulco, supra. Betsy testified as
follows regarding this trip:
Q [McDougal] Thank you. I’m going to ask you to move
back to [Exhibit] AQ again, this time page 19. The invoice
on page 19, both pages, show charges for the Acapulco
Princess in Mexico and a couple of other charges in Mexico,
and page 21 appears to show the backup charge slips for that
invoice.
Do you recall the purpose of the trip to Acapulco?
A [Betsy] The purpose was a spring vacation trip.
Q Did it have anything to do with the business of
Markette Corporation?
A Not specifically.
Petitioner’s analysis of the Sley Corporations business
purpose of this trip is as follows:
Betsy and petitioner travelled to destinations that
were conducive to business discussions, and business
discussions were held. (P.R.F. � 463). The Grossman house
was being renovated, (P.R.F. � 510), and was at that time an
unsuitable forum to discuss Sley System business. * * *
[There follows an attack on respondent’s expenditures of
“tax money he collects in cases like the one at bar.”]
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