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3 Markette’s cash disbursements journal shows the date as Nov.
10, but the check itself is dated Nov. 11.
4 Markette’s cash disbursements journal shows this item as check
No. 1877, the date as June 1, and the payee as National Seminar,
Inc. The bank’s debit memorandum itself shows the information
set forth in the table.
During the years in issue, petitioner, Betsy, and the
children usually flew to Miami to see Beatrice in December and in
the spring, and stayed for about one week. No notes or records
were kept of any Miami Sley Corporations’ business discussions.
Baybrook was never asked to make copies of the Sley Corporations’
financial statements to take to Miami, nor was Baybrook asked to
make travel arrangements.
Check No. 1862--Miami. In February 1983, five Eastern
Airlines tickets, costing $1,302, were bought for petitioner,
Betsy, and the children to fly to Miami to visit Beatrice. The
primary purpose of this trip was personal--a family vacation.
These tickets were paid for by Markette check No. 1862.
Check No. 1896--Lake Tahoe. The American Express July
invoice includes petitioner’s charges totaling $1,351.50 for five
United Airlines tickets for petitioner, Betsy, and their children
to fly round-trip from Washington, D.C., to Reno, Nevada. The
primary purpose of this trip was personal--a family vacation to
Lake Tahoe to visit relatives in the area (petitioner’s father
rented a condominium in Lake Tahoe) and to go skiing. These
charges were paid for by Markette check No. 1896. The family
usually went to Lake Tahoe in August. However, petitioner did
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