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on the location of the other entities, the service provided the
other entities, and Investments' conduct of a management
consulting service, we find that Investments’ maintenance of an
airplane was an ordinary expense. See Palo Alto Town & Country
Village, Inc. v. Commissioner, supra at 1390; Harbor Medical
Corp. v. Commissioner, T.C. Memo. 1979-291. Next, we must
examine whether the expense of maintaining the airplane was
necessary.
The airplane was used by Investments in the conduct of both
Rich Ford Sales and in the provision of management services. Use
of the airplane in either activity produced time and cost
savings. The airplane produced time savings in that it allowed
Investments’ employees to travel when necessary, not when
commercial flights were available; furthermore, the airplane
allowed Investments’ employees to visit more than one location in
a single day, which often could not be accomplished on a
commercial schedule. The airplane also saved other travel
expenses, as traveling in 1 day, instead of 2 or more days as
would be required via commercial airlines, saved room and board
expenditures. The airplane also allowed Investments to quickly
respond to emergency situations arising in either the Rich Ford
Sales business or in the management services activity. Based on
the foregoing facts and circumstances, we find that the ownership
and maintenance of the airplane were both appropriate and helpful
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