- 43 - 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 helpfulPage: 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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