- 39 -
same transaction. Likewise, the record does not enable us to
determine the purpose of either the check or the debit
memorandum.
There was no, or practically no, Sley Corporations business
purpose for the Hawaii trip, and the predominant purposes of the
Hawaii trip were personal and Grossman & Flask business.
Check Nos. 115417 and 1896--1984 Olympics. On August 12,
1983, Betsy bought $1,359.55 of tickets to the 1984 Olympics in
Los Angeles, and charged this on her Markette American Express
credit card. The tickets were used by petitioner, Betsy, and
their children to attend the 1984 Olympics. The purpose of this
trip was personal. Betsy told petitioner that she would
reimburse Markette for the cost of the Olympics tickets, but she
did not reimburse Markette.
Against the bill for the 1984 Olympics tickets, American
Express allowed credits on account of the $318 Lake Tahoe trip
ticket refund (Check No. 1896--Lake Tahoe, supra) and the $39.95
Hawaii trip ticket refund. Check No. 1896, Debit Memo--Hawaii,
supra. As a result, the American Express August invoice netted
to $1,001.60, which Markette paid by check No. 115417.
Check Nos. 1903, 1912--New York City. On September 29,
1983, Markette issued check No. 1903, in the amount of $496, to
American Express, to pay for round-trip airline tickets to New
York City. On November 11, 1983, Markette issued check No. 1912,
in the amount of $494.34, to American Express, to pay for hotel,
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