Ronald D. Ciaravella - Page 18

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          Oxford Dev. Corp. v. Commissioner, T.C. Memo. 1964-182; see also            
          Interstate Transit Lines v. Commissioner, 319 U.S. 590, 593-594             
          (1943); Deputy v. du Pont, 308 U.S. at 493-494.                             
               On the basis of the cost balances of aircraft on hand by               
          Dolphin as compared to the entire controlled group, we find that            
          the following are the percentages of the total cost of aircraft             
          of the entire group held for sale and lease which were owned by             
          Dolphin during the years in issue:                                          

                FYE 1991                 FYE 1992            FYE 1993                 
               41.2%                    38.0%               46.6%                     
               Because Mr. Ciaravella had interests in entities other than            
          Dolphin that owned aircraft, we are not convinced that the entire           
          amount spent by Dolphin on race car expenditures reasonably                 
          compares with the benefit that it, as opposed to other members of           
          the Ciaravella controlled group, could reasonably expect to                 
          derive.  When Mr. Ciaravella made contacts at the races, he was             
          trying to sell and lease aircraft held by Dolphin, Nomad, and               
          Sarasota, not Dolphin exclusively.  Consequently, Dolphin is not            
          entitled to deduct, on the Icarus consolidated return, the entire           
          amount of the race car expenses that it paid.                               
               Where a taxpayer establishes his entitlement to a deduction,           
          but does not establish the amount of that deduction, we are                 
          permitted to estimate the amount allowable, Cohan v.                        
          Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Rolland v.               
          Commissioner, T.C. Memo. 1959-161, affd. 285 F.2d 760 (5th Cir.             
          1961); Gill v. Commissioner, T.C. Memo. 1994-92; Boomershine v.             


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