Michael E. and Nancy Hentges - Page 5

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          qualification for a pilot's license, which he subsequently                  
          obtained.  The $9,826 shown above, therefore, includes the                  
          pilot/instructor fees just described.  The Mercedes automobile,             
          referred to above, was used exclusively in petitioner's business            
          activity as petitioners owned another vehicle, a Jeep Cherokee,             
          which they used for personal purposes.                                      
               With respect to the record keeping for all of the expenses             
          at issue, the only log petitioner maintained with respect to the            
          airplane was the log required by the Federal Aviation                       
          Administration (the FAA).  Petitioner stored this log in his                
          flight bag along with receipts incurred in connection with                  
          operation of the airplane.  Sometime during 1992, the flight bag            
          was stolen, and neither the bag nor its contents were ever                  
          recovered.  Under FAA regulations, petitioner was required to               
          reconstruct his flight log, and the information from the                    
          reconstructed log is what petitioner relies on here for                     
          substantiation of the expenses claimed in connection with the               
          airplane.5  To reconstruct the expenses for operation of the                
          aircraft for the period prior to the theft, petitioner simply               
          averaged the expenses he thereafter incurred and claims those               

               5    The log itself was not introduced into evidence,                  
          although petitioner submitted a "Reconstruction of Travel Expense           
          Log", which presumably contains the same information that the FAA           
          log contains.  However, the document introduced into evidence               
          covers the entire year 1992, even though petitioner testified               
          that the FAA log was reconstructed only up to the date of the               
          loss of the original log.                                                   




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