- 119 - 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.Page: Previous 109 110 111 112 113 114 115 116 117 118 119 120 121 122 123 124 125 126 127 128 Next
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