- 44-
used the arithmetically correct figure, $13,542.26, in
calculating the total constructive dividend amount and thus used
the arithmetically correct total in determining the 1984
deficiency.
Check No. 2008--Orlando. As payment for the American
Express September invoice, Markette issued check No. 2008,10 for
$1,576, to American Express on October 8, 1984. By this check,
Markette paid for five Eastern Airlines tickets appearing on the
August invoice and a Pan American World Airways ticket appearing
on the September invoice.
The Markette American Express invoice with a closing date of
October 17, 1984, shows charges for five Eastern Airlines
tickets, costing $780, and no other charged items. The October
invoice also shows the $1,576 payment made with check No. 2008
and a $860 credit on account of the return or cancellation of
five Eastern Airlines tickets that had appeared on the August
invoice. The October invoice charges were on Betsy’s card. The
October invoice had a credit balance of $80, the net of the $780
charges and the $860 credit.
The five Eastern Airlines tickets on the October invoice
were bought for petitioner, Betsy, and the children to fly from
Washington, D.C., to Orlando, Florida, on September 27, 1984, and
back on September 30, 1984. The purpose of this trip was
10 The notice of deficiency shows this as check No. 2007.
However, it is clear from the context that 2008 is intended.
Page: Previous 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 NextLast modified: May 25, 2011