- 93 -
We conclude, and we have found, that the trip to Miami was
primarily of personal nature. Markette’s payment of $1,302 of
the expenses of this trip constitutes a constructive dividend to
Betsy from Markette in this amount.
We hold for respondent on this issue.
Hawaii
Markette paid $2,014.69 of charges that petitioner made on
his Markette American Express credit card that was associated
with a trip to Hawaii taken by petitioner, Betsy, and the
children. Of this amount, a $39.95 airline ticket related to the
Hawaii trip later was refunded by way of a credit against the Los
Angeles Olympics tickets bill, discussed infra. Respondent also
contends that the $3,311.82 debit memorandum dated June 2, 1983,
was an expenditure by Markette associated with the trip to Hawaii
and that this expenditure had a primarily personal purpose. We
have found that the primary purposes of the trip to Hawaii were
(1) for petitioner to appear as a panelist on a video conference
to be broadcast from Hawaii by satellite, (2) meet Ruff in
person, and (3) to take a family vacation. See Findings Check
No. 1896, Debit Memo--Hawaii, supra.
Petitioner’s appearance on the video conference may have
been significant in enhancing his reputation as a tax lawyer,
although it appears to have netted him only one client, but no
Sley Corporations purpose has been suggested as being served by
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