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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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