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$16,500 in cash and obtained a $148,500 mortgage. Petitioners
paid points on that loan. Petitioners deducted $4,457.50 on
their 1992 Schedule A for the points petitioner paid relating to
both houses.
Petitioners had receipts for these three transactions but
lost them. Petitioners did not contact the banks that arranged
the financing to get copies of these documents.
F. Airplane Leasing
Petitioners bought an airplane for $7,700 on January 22,
1991. Mr. Frank did not know how to fly when they bought the
airplane. He learned how to fly 2 or 3 years later.
Petitioners bought the airplane with the intent of making
a profit. Petitioners leased it to General Aviation Pilots
Association (GAPA) from January 22, 1991, to July 15, 1991, and
to Slant Alpha Inc., Flight Training (SAFT) from July 1991 to
the end of 1991. GAPA and SAFT rented the airplane to people
learning how to fly. GAPA and SAFT paid for fuel, oil,
maintenance, inspection fees, insurance, and parts. GAPA and
SAFT sent statements to petitioners showing the airplane's income
and expenses. GAPA or SAFT paid petitioner the profit if the
airplane's income exceeded its expenses. If the airplane's
expenses exceeded its income, petitioners paid the difference to
GAPA or SAFT.
Mr. Frank, with a mechanic, changed the airplane's oil,
removed screws from the inspection plates, and tied down and
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