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The inconvenience that petitioners would have experienced a
few times a year in flying to the Oregon timber farm via
commercial air carrier we regard as minimal, as ordinary, and as
common, both for individuals and for businessmen. That
petitioners -- as an ordinary and necessary business expense
under the facts of this case -- would incur the extravagant
costs of purchasing and maintaining a Lear jet to avoid such
infrequent and slight inconvenience has not been established.
See Harbor Med. Corp. v. Commissioner, T.C. Memo. 1979-291,
affd. without published opinion 676 F.2d 710 (9th Cir. 1982);
Bullock's Dept. Store, Inc. v. Commissioner, T.C. Memo. 1973-
249; Hatt v. Commissioner, T.C. Memo. 1969-229, affd. 457 F.2d
499 (7th Cir. 1972); cf. Palo Alto Town & Country Village, Inc.
v. Commissioner, 565 F.2d 1388 (9th Cir. 1977), revg. in part
and remanding T.C. Memo. 1973-223; Noyce v. Commissioner, 97
T.C. 670, 688 (1991).
We conclude that petitioners, for the years before us,
should be allowed (with respect to each of the trips from
Orange, California, at which was located petitioner's consulting
and computer and real estate rental businesses, to their Oregon
timber farm) a business travel expense deduction under section
162 for the estimated or constructive travel expenses that
petitioners would have incurred based on first class air fare.
With regard to the constructive expenses of transporting
equipment and machinery that petitioners apparently transported
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