- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011