E.W. Richardson - Page 41

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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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