- 23 - 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 viewedPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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