- 44 - to Investments; accordingly, we find the expenditures arising from the ownership and maintenance of the plane were necessary. Finally, respondent argues that the airplane expenditures were unreasonable in amount compared to the objectives to be accomplished. Investments’ total costs of owning, operating, and maintaining its airplane, exclusive of pilot salary, during 1988 and 1989 were $218,452.14 and $142,427.85, respectively. However, as noted above, we have found that the airplane was both an ordinary and necessary expense of the operation of Investments’ Rich Ford Sales division and the operation of its management services activity. The latter activity alone generated management fees of $814,452 and $970,997 for taxable years 1988 and 1989, respectively. In addition, Investments received reimbursements for airplane expenditures of $48,048.50 and $37,674, exclusive of meals, lodging, etc., for 1988 and 1989, respectively. Although the airplane expenditures were large for the taxable years at issue, use of the airplane was an ordinary and necessary part of Investments' businesses and generated substantial income during the years at issue. Accordingly, we find that the expenditures associated with owning and maintaining the airplane for the years at issue were reasonable. To reflect the foregoing, Decision will be entered under Rule 155.Page: Previous 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44
Last modified: May 25, 2011