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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 its
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