- 41 - secondary and incidental use of the airplane. Rather, respondent focuses on petitioner’s relationship with the other entities and the use of the airplane in providing management services to those entities. During the taxable years at issue, the airplane was used to transport Investments’ employees to six of the other entities so that the employees could provide management services. Since petitioner had an ownership interest in five of these six entities, respondent argues that the airplane was used primarily to benefit petitioner as an owner of these entities, not to benefit Investments. Basically, respondent argues that the airplane was used to improve the value of the other entities by making Investments’ employees available for management consultations. It is true that the airplane facilitated the availability of Investments’ employees to the other entities. Accordingly, assuming the management services were beneficial to the other entities, it is true that the expenses of the airplane benefited petitioner, since he had an ownership interest in all but one of the other entities serviced during the taxable years at issue. Nonetheless, we find this was an incidental benefit of the acquisition and maintenance of the airplane. We find that Investments owned and maintained the airplane primarily for the benefit of its business-related activities, including its management services activity and its Rich Ford Sales activity. Investments charged substantial fees for itsPage: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 Next
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