Robert D. Grossman, Jr. - Page 148

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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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