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logs provide very little information to satisfy what section
274(d) and the regulations require. With respect to the
airplane, virtually all of the receipts for payment of the pilot
are specified to be for flight instructions rather than for pilot
services.
Petitioners did not contend that expenses for petitioner's
flight training were deductible expenses but contended that such
expenses were incurred during a trade or business activity.
However, the logs petitioners submitted into evidence and some of
the receipts contradict petitioners' claim that expenses for the
flight instructor were claimed only in connection with flights
involving petitioner's business. For example, included in
petitioner's documentation is a receipt dated December 15, 1992,
in the amount of $300, from petitioner's flight instructor. The
travel log submitted into evidence does not reflect any business
travel involving use of the airplane on December 15, 1992.
Moreover, the Meals Entertainment Log offered into evidence shows
that petitioner had a meal on December 15, 1992, at "Chili's"
restaurant with a Rusty Hargrove. While the location of this
restaurant is not indicated, it appears to the Court that this
restaurant was probably a local restaurant. Petitioner's
presence in Tulsa, Oklahoma, that day contradicts his claim that
he was on business travel that day in the airplane. There are
several other similar instances of contradictions in petitioner's
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