- 94 -
this appearance.27 Petitioner’s opportunity to meet Ruff might
conceivably have served a Sley Corporations purpose, but we have
no information suggesting that petitioner or Betsy learned, or
even sought to learn, anything from Ruff that would have been of
use to the Sley Corporations.
Petitioner’s role in the video conference on Oahu lasted
only about a few hours, with perhaps some studio preparation the
day before. Petitioner and Betsy visited Ruff’s operations on
Maui, but the record does not indicate that this was anything
more than a walk-through. On the other hand, petitioner, Betsy,
and the children were in Hawaii for 10 days or more. Thus,
substantially all of the time that petitioner, Betsy, and the
children spent in Hawaii was spent having a family vacation--
clearly a personal purpose and not a Sley Corporations’ business
purpose.
We conclude, and we have found, that there was no, or
practically no, Sley Corporations business purpose for the Hawaii
trip, and the predominant purposes of the Hawaii trip were
personal pleasure and Grossman & Flask business.
However, we do not agree with respondent’s contention that
Betsy should be charged with $5,326.51 constructive dividend
27 Petitioner has not contended for, or pointed to
evidence as a basis for, any allowance of an offsetting deduction
on account of his trade or business as a lawyer.
Page: Previous 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 NextLast modified: May 25, 2011