Stanley M. Kurzet and Anne L. Kurzet - Page 23

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            approximately 9 hours and would involve two stops and at least                            
            one change of planes.                                                                     
                  During the years in issue, petitioner paid a full-time pilot                        
            approximately $30,000 a year to fly the Lear jet.  Petitioner                             
            also was a pilot and served as the second pilot required to fly                           
            the Lear jet.                                                                             
                  After flying petitioners to Oregon and to the Tahiti                                
            Property, and while waiting to fly petitioners back to California                         
            or Utah, the pilot, at petitioner’s request, would often assist                           
            with various projects at the timber farm and at the Tahiti                                
            Property.                                                                                 
                  The Lear jet operating expenses for 1987, 1988, and 1989,                           
            including depreciation totaled $667,709, $728,201, and $402,399,                          
            respectively.                                                                             
                  Petitioner sold the Lear jet in 1994 for $2.45 million.                             
                  For purposes of their books and records and their income tax                        
            return treatment of expenses of operating the Lear jet,                                   
            petitioners each year made an allocation of expenses of the Lear                          
            jet between what petitioners regarded as business and as personal                         
            use.  For example, with regard to a trip from Los Angeles to Salt                         
            Lake City on February 6, 1989, for the stated purpose "to see                             
            condo, conferring with architect, and ski", the total 1.4 hours                           
            each way for the Lear jet were allocated by petitioners .7 hour                           
            for personal and .7 hour for business, because petitioners viewed                         






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