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petitioner in Brallier raced a stock car to advertise his wholly
owned corporation's pizza restaurant franchise. The petitioner
in Boomershine raced a car to advertise his wholly owned
corporation that erected metal buildings. The connection between
the excitement and appeal of racing cars and owning and flying in
high performance jet aircraft is much stronger than the
connection between racing cars and selling stencils, pizza, or
metal buildings.
Notwithstanding the foregoing, we still do not find that the
expenses are entirely reasonable in amount. In determining the
extent to which advertising expenses are reasonable, we compare
the amount expended for the activity in question with the amount
of benefit reasonably expected to be derived. Lang Chevrolet Co.
v. Commissioner, T.C. Memo. 1967-212; see also Sanitary Farms
Dairy, Inc. v. Commissioner, 25 T.C. 463 (1955); Rodgers Dairy
Co. v. Commissioner, 14 T.C. 66 (1950).
We have found that Mr. Ciaravella's racing activities were
calculated to help sell and lease aircraft. But the aircraft he
was trying to sell were not only owned by Dolphin, but also by
Sarasota and Nomad, corporations within the same controlled group
as Dolphin, but not included with Dolphin on the Icarus
consolidated return. It is axiomatic that in order for an
expense to be deductible by a taxpayer, it must be incurred in
the taxpayer's own trade or business, not that of another.
Columbian Rope Co. v. Commissioner, 42 T.C. 800, 814-816 (1964);
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