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in connection with a trip petitioner took to Philadelphia to do
Pennsylvania State tax work for one of the Sley Corporations.
Check No. 2162--Miscellaneous Washington, D.C. Miscel-
laneous hotel, airlines, restaurant, and theater expenses,
totaling $797.21, appear on the American Express April invoice.
These expenses were incurred by petitioner and Betsy in the
Washington area. These expenses were paid for by check No. 2162.
The record does not provide an adequate basis for findings as to
the purposes of these expenses.
Check No. 2220--Miami. The American Express November
invoice includes charges totaling $1,570.50 for six round-trip
Eastern Airlines tickets to Miami. Three of the tickets cost
$299 each, and the other three cost $224.50 each. The tickets
were for Betsy, the children, probably petitioner, and another
adult. Betsy charged the tickets on October 10, 1986. These
tickets were paid for by Markette check No. 2220. Respondent
conceded that two of the adult tickets ($598) were for business
purposes and reflected this concession in the notice of
deficiency. The remaining expenses were for personal purposes--a
family vacation.
Check No. 2220--American Express Fee. The American Express
November invoice includes a charge of $45 as the annual
membership fee for Betsy’s American Express credit card. This
business expense was paid for by Markette check No. 2220.
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