Robert D. Grossman, Jr. - Page 101

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          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.                




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