Robert D. Grossman, Jr. - Page 156

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          for himself, Betsy, and the children to go to the Los Angeles               
          Olympics in 1984, and we do not perceive any such business                  
          purpose.                                                                    
               Petitioner testified that Betsy told him that she would                
          reimburse Markette, but she did not in fact reimburse Markette.             
               We conclude, and we have found, that the tickets to the 1984           
          Los Angeles Olympics were personal.  Respondent proved by clear             
          and convincing evidence that Markette paid $1,359.55 for these              
          tickets.  Thus, Betsy received a $1,359.55 constructive dividend            
          from Markette.                                                              
               We hold for respondent on this issue.                                  
               New York                                                               
               Markette paid $496 for airfare and $494.34 for hotel and               
          meals for a trip to New York, N.Y., on September 9, 1983, and a             
          return on September 11, 1983, for petitioner, Betsy, and the                
          children.  See Findings Check Nos. 1903 and 1912--New York City,            
          supra.  On opening brief, petitioner “concedes that any travel              
          related to the children is a constructive dividend.”  As detailed           
          in our findings, supra, of the total $990.34, we have attributed            
          $520 to the children and the remaining $470.34 to petitioner and            
          Betsy.                                                                      
               We have accepted petitioner’s and Betsy’s testimony to the             
          effect that the purpose of this trip was for petitioner and Betsy           
          to go to the “diamond district” in New York City to talk with               





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