- 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 Next
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