Robert D. Grossman, Jr. - Page 151

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          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.                            





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