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Airplanes
Petitioner owned the following four airplanes during 1988
and 1989:
Airplane Date Acquired Date Disposed OfPurchase Price
1963 Piper PA30 July 1982 July 1989 $ 22,500
1972 Cessna 150 July 1986 July 1989 7,500
1956 Cessna 172 July 1989 Not applicable Even trade for
Piper PA30
1970 Mitsubishi MU2BJuly 1989 Not applicable 175,000
Petitioner's airplanes were used by him personally and by Allied
as follows:
1988 1989
Business usage (hours) 92 135
Petitioner's usage (hours) 81 179
Total hours 173 314
During 1988, Allied's use of petitioner's airplanes was
53 percent of the total usage. During 1989, Allied's use of
petitioner's airplanes was 43 percent of the total usage. During
1988, Allied paid for all operating expenses of petitioner's
airplanes, including those expenses attributable to personal use.
Petitioner paid at least $40,009 of airplane expenses during
1989.
Petitioner's airplanes were flown the following number of
hours during the years in issue:
Airplane 1988 1989
1963 Piper PA30 150.0 96.5
1972 Cessna 150 22.8 13.9
1956 Cessna 172 --- 2.2
Mitsubishi MU2B --- 201.4
Aztec (rental airplane) --- 7.5
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Last modified: May 25, 2011