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approximately 17 miles. The record does not reveal the distance
between the corporate office of Roy, Inc., and the other hospitals
to which Mohan Roy traveled.
During the years in issue, Roy, Inc. owned a 1990 Silver Spur
II Rolls Royce. It also owned a 1988 Mercedes Benz S-500 until
1993, at which time that automobile was traded in connection with
the corporation's leasing a new Mercedes Benz S-500.
Because they worked at different hospitals at different times,
the Roys were not able to travel together. During the years in
issue, Vimal Roy generally drove the Mercedes Benz S-500. The
parties agree that the Roys' personal use of the Mercedes Benz S-
500 owned by Roy, Inc., during each of the years in issue was 28
percent and that the individual petitioners received constructive
dividends as a result of such use during each of the years in
issue.
The Roys personally owned three automobiles: A 1990 Lexus
400, a Range Rover, and a General Motors pickup truck. The Range
Rover was insured under Roy, Inc.'s policy but was primarily used
by the Roys' son who was in medical school.3
3 The purpose of having the Range Rover as well as the
Rolls Royce and two other vehicles on Roy, Inc.'s insurance
policy was to obtain a multiple-car discount on the premiums.
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