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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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