- 48 - 15, 1984, and returned on November 21, 1984. The primary purpose of the trip was personal--to see Beatrice. This charge was paid for by Markette check No. 2036. Check No. 2036--Miami--Children. The American Express December 1984 invoice includes charges totaling $397 for three Eastern Airlines one-way tickets for the children from New York City to Miami. Betsy bought the tickets on December 3, 1984. The children left New York on December 26, 1984.11 Petitioner, Betsy, and the children had gone to New York City for Christmas. It was intended that all five of them would go to Miami to meet with Beatrice--a personal family vacation purpose. However, petitioner had some business to do in Washington, D.C., before the end of the year, so he and Betsy returned to Washington, D.C., from New York City, while the children went directly from New York City to Miami. A few days later, petitioner and Betsy went on to Miami to meet Beatrice. These charges for the children’s three tickets were paid for by Markette check No. 2036. 11 Petitioner’s proposed finding of fact 507 indicates that this trip was on Dec. 26, 1987, and on answering brief respondent does not dispute the date. Even if we were to regard the parties’ agreement on this point as a supplemental stipulation, we would disregard the stipulation because it is contrary to the persuasive evidence in the record that the trip was on Dec. 26, 1984. Jasionowski v. Commissioner, 66 T.C. 312, 318 (1976).Page: Previous 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 Next
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