- 113 - 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.Page: Previous 103 104 105 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 Next
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