- 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 Next
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