- 56 -
Less adjustment (788.07)
Total 11,659.62
1 The total amounts for check Nos. 2137, 2162, and 2220 are
$6,750.65, $4,713.94, and $1,615.50, respectively. The check
amounts listed in table 11 are the net amounts respondent
determined were constructed dividends.
Check Nos. 2137, 2148, and 2203--Miami. Petitioner or his
family traveled to Miami in late November 1985, in January 1986,
and in February 1986. Of the net $5,424.86 expenses for these
three trips charged on Markette American Express credit cards,
$4,265.28 was paid for by Markette check No. 2137,14 $438 was
paid for by Markette check No. 2148,15 and $721.58 was paid for
by Markette check No. 2203.
On November 14, 1985, Betsy bought six round-trip Eastern
Airlines tickets to Miami, to leave Washington, D.C., on November
27 and return on December 1. Three of the tickets cost $399 each
14 In the notice of deficiency, respondent allowed as Sley
Corporations business expenses $1,674 of the expenses paid for by
Markette check No. 2137. At trial, respondent’s revenue agent
testified that the allowed $1,674 “related to November `85,
January `86 and February `86 airfare to Miami.” Neither side has
offered, and we have been unable to discover, a likely
identification of which are the items of the total $4,265.28
Miami expenses paid by check No. 2137 that respondent determined
to be includable in petitioner’s and Betsy’s income, and which
are the items in the $1,674 not so includable.
15 For some reason undisclosed by the record, Markette
check No. 2137 was not used to pay the charges shown on one of
the four pages of the American Express Jan. 1986 invoice.
Instead, the two $219 Eastern Airlines charges on that page were
paid together with American Express Feb. 1986 invoice items by
Markette check No. 2148. See infra Check No. 2148--Betsy’s
Western Trip.
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