E.W. Richardson - Page 43

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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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