Robert D. Grossman, Jr. - Page 116

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          2137, 2148, and 2203, but rather is properly attributable to one            
          of the trips paid for by check No. 2162.  Thus, the net Miami               
          trip expenses paid for by check No. 2137 are $4,265.28.                     
               The primary purpose of Betsy’s Denver-Miami trip ($399) and            
          the Miami mid-February hotel stay ($322.58) was personal.  The              
          primary purpose of $1,674 of the Miami trips’ expenses that                 
          appeared on the American Express December 1985 and January 1986             
          invoices was Sley Corporations business (see supra note 14).                
          The $438 paid for by check No. 2148 was not included in the                 
          $1,674 Sley Corporations business expenses.  The primary purpose            
          of the remaining $2,591.28 of these expenses paid for by check              
          No. 2137 was personal.                                                      
               Check No. 2137--Snowmass.  The American Express December               
          1985 invoice includes charges totaling $1,693.22 for four round-            
          trip United Airlines tickets to Aspen, Colorado.  The ticket for            
          Betsy cost $521 and the other three tickets cost $390.74 each.              
          Betsy bought the tickets on November 19, 1985.  The American                
          Express January 1986 invoice includes a $326.15 charge for a stay           
          at the Silvertree Motel at Snowmass Village, Colorado.  The                 
          $2,019.37 total of these Snowmass expense charges were paid for             
          by Markette check No. 2137.  The purpose of this trip was to take           
          a Christmas vacation to Snowmass, a ski resort near Aspen,                  
          Colorado.  Although petitioner did not go on this trip, he knew             
          that Betsy and the children were going to Snowmass.                         






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