- 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 Next
Last modified: May 25, 2011