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Secondly, petitioner did not go on that trip, so he could not
have “looked at investment properties” with Betsy on that trip.
Thirdly, Betsy testified that she never did anything about the
alleged investment property examination.
We are satisfied that respondent has shown by clear and
convincing evidence that the 1983 Lake Tahoe trip was for
personal pleasure and not for Sley Corporations’ business, and
that Markette’s payment of the cost of the airline tickets
constituted income to Betsy, reportable on petitioner’s and
Betsy’s 1983 joint tax return.
However, we do not agree with respondent’s contention that
petitioner and Betsy should be charged with $1,351.50
constructive dividend income on account of this trip. We have
found that $318 of the amount Markette paid by its check No. 1896
on account of this trip was refunded to Markette by way of a
credit against the Los Angeles Olympics tickets bill discussed
infra. As we understand respondent’s contentions, respondent
includes the $318 in the Lake Tahoe trip expenses (because that
was paid as part of Markette’s payment of the American Express
July 1983 invoice) and also includes the $318 in the Los Angeles
Olympics expenses (because the credit was used against the charge
for Olympics tickets paid as part of Markette’s payment of the
American Express August 1983 invoice). This is improper double-
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