Robert D. Grossman, Jr. - Page 31

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          which of the disputed expenditures are being allowed, and in what           
          amounts.  Thus, we construe these allowances against respondent.            
               We also reduce the $13,322.32 figure by $1,241.21, as                  
          follows:  (1) $797.21 of miscellaneous Washington area expenses,            
          as we found that the record does not support a finding that these           
          expenditures had a personal purpose, see supra Check No. 2162--             
          Miscellaneous Washington, D.C., (2) $45 annual membership fee               
          that we found had a business purpose, see supra Check No. 2220--            
          American Express Fee, and (3) $399 refund of one of the five                
          Washington-Miami tickets, see supra Check Nos. 2137, 2148, and              
          2203--Miami.                                                                
               We hold for respondent to the extent of $5,963.43                      
          ($13,322.32 less $6,117.68 and less $1,241.21) and for petitioner           
          to the extent of $7,358.89 ($6,117.68 plus $1,241.21), on this              
          issue.                                                                      
          (5) Conclusions                                                             
               Table 19 shows the amounts of constructive dividends Betsy             
          received from Markette that petitioner and Betsy omitted from               
          their 1983 through 1986 tax returns.                                        













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