- 116 -
Betsy, reportable on petitioner’s and Betsy’s 1985 joint tax
return.
We hold for respondent on this issue.
Los Angeles
Markette paid $457 for petitioner’s airfare from Los Angeles
to Washington, D.C., that petitioner charged on his Markette
American Express credit card. See Findings Check No. 2100--Los
Angeles, supra.
Respondent asked Betsy about the airline ticket, and Betsy
testified that she did not remember anything about the trip and
did not “specifically” remember anything about petitioner’s being
in Los Angeles on Sley Corporations business. Respondent did not
ask petitioner about the trip, and petitioner did not testify
about it.
Respondent has failed to show by clear and convincing
evidence that petitioner’s Los Angeles trip was for personal
purposes and provided a benefit to Betsy.
We hold for petitioner on this issue.
Summary--1985
Our fraud issue holdings as to 1985 constructive dividends
are summarized in table 18.
Page: Previous 106 107 108 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 NextLast modified: May 25, 2011