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telephone, and meal expenses in New York City. All the charges
were on Betsy’s Markette American Express credit card, but
petitioner signed the credit slips for the hotel, etc., expenses.
The expenses were incurred for a trip by petitioner, Betsy, and
the children to New York City on September 9, 1983, and back on
September 11, 1983. The purpose of this trip was for petitioner
and Betsy to go to the “diamond district” in New York City to
talk with diamond brokers about selling the Sley Corporations’
diamonds. Petitioner and Betsy took GIA certificates on their
visits to the diamond district, but did not take the actual
diamonds. Petitioner and Betsy did not keep notes or records of
their discussions with the diamond brokers, nor did they get
written quotations on the value of their diamonds.
The children were ages 13, 10, and 7 at the time of this New
York trip. Petitioner and Betsy took the children to New York
City because it was more convenient to take the children with
them than to get a babysitter for the children in Maryland.
Petitioner’s and Betsy’s airline tickets cost a total of
$220; the children’s tickets a total of cost $276. Petitioner,
Betsy, and the children took two rooms at the Grand Hyatt New
York; the cost (including taxes) of each room for the two nights
was $183.70. Telephone call charges total $7.18. Charges for
meals total $119.76.
This New York City trip was taken for Sley Corporations
business purposes and was not a personal or family vacation or
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