- 117 -
Table 18
Respondent’s Contention
1985 Trip on Brief Court’s Holding
Miami $397.00 $397.00
Miami 2,166.00 --
Lake Tahoe 630.00 630.00
Acapulco 3,682.24 3,682.21
Stamford 349.63 59.63
Corpus Christi 1,137.50 1,137.50
San Diego 450.00 450.00
Canada 3,610.37 3,610.37
Los Angeles 457.00 --
Totals 12,879.74 19,966.71
1 Table 10, supra, shows that we found that Betsy had $10,164.71
of constructive dividend income from 1985 Markette payments for
personal travel and entertainment expenses. The $198 difference
between that amount and the $9,966.71 shown in table 18 is
accounted for by Betsy’s round-trip ticket to Miami, described in
our findings of Check No. 2036--Miami--Betsy, supra. Respondent
included that item in the notice of deficiency, but not in the
listing of fraudulent items.
(4) 1986
On answering brief, petitioner contends as follows:
12. 1986 trips.
Respondent contends at pages 124 - 126 of her
[opening] brief that Betsy had constructive dividend
income from corporate expenditures which was
fraudulently omitted from petitioner’s 1986 joint
return. Petitioner in his Opening Brief at pages 177 -
184, inclusive, argues that he is an innocent spouse
for 1986. Petitioner relies on his innocent spouse
argument as his response to respondent’s 1986
constructive dividend claim. Petitioner neither signed
nor saw Markette’s 1986 tax return. P.R.F. � 255(A).
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