Stanley M. Kurzet and Anne L. Kurzet - Page 48

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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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