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We hold for respondent as to $59.63, and for petitioner as
to $290, on this issue.
Corpus Christi
Markette paid $1,137.50 for round-trip airfare to Corpus
Christi, Texas, for Betsy and the children. See Findings Check
No. 2098--Corpus Christi, supra.
Betsy testified as follows regarding this Corpus Christi
trip:
Q [McDougal] Do you remember the purpose of the trip?
A [Betsy] I think my mother was out there and I think
I had gone out there to meet with my mother and my brother.
Q And was that for the business of Markette
Corporation.
A I think there was some business that was discussed.
Q Was that the primary purpose of the trip?
A I don’t remember specifically.
Q What interest did Markette Corporation have in
having your children go to Corpus Christi?
A I don’t know. I mean all these bills were given
over to Harvey Berger and it was not my procedure to ever
really question what was done with these things.
Respondent has shown by clear and convincing evidence, and
we have found, that Betsy’s and the children’s Corpus Christi
trip was for personal purposes and not for Sley Corporations’
business. We conclude that Markette’s payment of the $1,137.50
airfare constituted constructive dividend income to Betsy,
reportable on petitioner’s and Betsy’s 1985 joint tax return.
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