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Fiesta Dodge were located in San Antonio, Texas. Heritage was
located in Kirkland, Washington, and Sunland in Apple Valley,
California. The airplane allowed Investments’ employees to
provide management services in person to each of these out-of-
town dealerships.
Investments generally used the airplane only if four or more
people needed to travel. If fewer than four people were
traveling, the employees would usually fly commercially, as use
of the airplane in such circumstances was inefficient. Use of a
private airplane saved time, as employees could fly to an out-of-
town dealership and return to Albuquerque, New Mexico, in the
same day, or they could visit two dealerships in the same day.
This was important, because the down time associated with having
a number of employees waiting for a commercial flight was costly.
Use of the private airplane also saved travel expenses, because
the reduced travel time often reduced the room and board costs
that would be associated with commercial travel.
Overall, the airplane was flown a total of 112.98 and 68.30
hours for taxable years 1988 and 1989, respectively. The
airplane was flown 63.77 and 52.30 hours for management services
for taxable years 1988 and 1989, respectively. Accordingly, the
airplane was used 56 percent and 77 percent of the time in 1988
and 1989, respectively, for management services.
The airplane was also used to fly employees to conventions,
seminars, and training in 1988. It was used 12.86 hours for this
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Last modified: May 25, 2011