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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).
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