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with them to Oregon in their Lear jet, petitioners have provided
no basis on which we can estimate what such transportation
expenses would have been. The evidence does not specifically
itemize or adequately describe any of the equipment or machinery
so transported, its weight, or size. On the evidence before us,
we are unable to estimate constructive transportation expenses
of equipment and machinery to petitioners' Oregon timber farm.
In summary, the use of a private Lear jet by petitioners in
connection with their Tahiti Property we regard as personal.
Even for a businessman as successful, busy, and wealthy as
petitioner, on the facts of this case, we regard petitioners'
use of a Lear jet in connection with travel to their timber farm
in Oregon as extravagant and not ordinary and necessary.
Because of the substantial personal aspect of petitioners'
travel to Utah (namely, to ski and to purchase and build a
personal residence), we decline to make any attempt to estimate
what portion of petitioners' claimed travel expenses to Utah
might arguably be deductible as relating to the two rental
condominiums that petitioners owned in Park City, Utah. The use
of the Lear jet in connection with petitioners' travel to Utah
we regard either as personal (and relating to petitioners'
skiing and personal residence that was being constructed in Park
City, Utah), or as extravagant and as not qualifying as ordinary
and necessary expenses of the two condominium rental units that
petitioners owned in Utah.
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