Stanley M. Kurzet and Anne L. Kurzet - Page 47

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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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