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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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