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Betsy; where it was supported by Betsy, in almost all instances
Betsy’s testimony was no more believable on this point than
petitioner’s. For example, we simply do not believe that
petitioner, Betsy, and the children spent thousands of dollars to
travel to Miami during the 6 months or so each year that Beatrice
was there, simply to facilitate Sley Corporations business
discussions, or even in significant part to have such
discussions. We do not believe Betsy’s testimony that, when she
and the children were in Miami for a week she and Beatrice spent
1-2 hours a day discussing Sley Corporations business.
We consider the disputed items year-by-year and, for any
year, trip-by-trip in the order appearing supra in table 15.
(1) 1983
Miami
Markette paid $1,302 airfare for petitioner, Betsy, and the
children to fly to Miami in early 1983 to visit Beatrice.
See Findings Check No. 1862--Miami, supra.
In the context of the entire record, we are convinced that
the Miami trips in general, and this early 1983 Miami trip in
particular, were primarily personal and that Sley Corporations’
business, if it was discussed at all, was at most an incidental,
side aspect.
The personal nature of the Miami trips is demonstrated by
the fact that these were trips taken by the entire household to
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