Robert D. Grossman, Jr. - Page 98

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          sightseeing trip.  However, there were no Sley Corporations                 
          business purposes for the children’s presence on this trip; their           
          presence was for Betsy’s personal purposes.  Of the $990.34 of              
          expenses paid by Markette ($496 airline plus $494.34 hotel,                 
          etc.), $520 (the children’s airline tickets, one of the hotel               
          rooms, and about half the meals) is attributable to the children            
          and the remaining $470.34 is attributable to petitioner and                 
          Betsy.                                                                      
               Summary.                                                               
               The record does not provide an adequate basis for findings             
          as to the purposes of the other expenditures listed supra on                
          table 5.                                                                    


               Table 6 shows our allocations with respect to respondent’s             
          determinations listed supra on table 5.                                     

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