- 43-
1984
Table 7 lists certain checks written on the Markette account
in 1984. The table shows the date the check was written, check
number, payee, and amount. All of these checks, except for check
Nos. 1951, 1975, and 1995, were signed by petitioner. Check No.
1951 was unsigned (but was processed and paid, anyway), check No.
1975 was signed by Betsy, and check No. 1995 does not appear in
the record. Respondent determined that petitioner and Betsy
omitted to report $14,894.26 of constructive dividends received
from Markette in 1984, the sum of the checks listed in table 7.
In the notice of deficiency, this figure was adjusted downward by
$1,214 for the amount of check No. 1995 and by $138 for a travel
and entertainment reimbursement. See supra note 9.
Table 7
Check
Date Number Payee Amount
Jan. 09 1929 American Express $2,526.53
Feb. 21 1946 Eastern Airlines 1,616.50
Mar. 12 1951 American Express 800.00
Mar. 13 1952 American Express 1,840.28
Apr. 17 1966 American Express 930.75
May 25 1975 American Express 694.20
July 20 1987 United Airlines 2,057.00
Aug. 02 1993 American Express 1,399.00
Aug. 31 1995 American Express 1,214.00
Sept.19 2003 Sean Henry 240.00
Oct. 08 2008 American Express 1,576.00
14,894.26
Less adjustments 1,352.00
Total 113,542.26
1 In the notice of deficiency, respondent made a mathematical
error and stated this figure as $13,452.26. Respondent, however,
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