- 33 - petitioner's labor was contributed, and no wage or fee was paid to petitioner for his labor on the timber farm). Petitioners' total $147,643 cost for purchase and improvement of the mobile unit was capitalized, and depreciation thereon was claimed by petitioners as an expense of the timber farm. The primary difference between petitioners’ original Federal income tax returns and petitioners’ proposed revised Federal income tax returns, all of which were prepared by accountants and experienced tax return preparers, relates to the Lear jet. On petitioners’ original Federal income tax returns, the Lear jet was treated as a separate trade or business activity, and all noncapital costs thereof were treated as current business expenses, including depreciation. On the proposed revised returns, the Lear jet is not treated as a separate business activity. Rather, based on the Lear jet’s flight logs, the noncapital costs of the Lear jet (including depreciation) are allocated to the various separate other activities of petitioners and treated as deductible section 162 business expenses, deductible section 212 expenses, or as nondeductible personal expenses depending on the business, investment, or personal nature of the underlying activity to which the expenses are allocated. On petitioners’ proposed revised Federal income tax returns, petitioners treat their Tahiti Property as a for-profitPage: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
Last modified: May 25, 2011