Mark and Helen Thomson - Page 3




                                        - 3 -                                         
          they filed the petition.                                                    
               During the years at issue, petitioner Mark Thomson (peti-              
          tioner or Mr. Thomson) operated a business known as Aviation                
          Warehouse (Aviation) which rented aircraft parts to motion                  
          picture studios (movie studios) for use in film production.                 
          Aviation also sold photocopies of pages from books on aircraft in           
          a library that it maintained for that purpose.                              
               During the years at issue, Mr. Thomson purchased most of the           
          aircraft parts and books used in Aviation’s business activities             
          at auctions held throughout the United States.  At those auc-               
          tions, petitioner usually obtained aircraft parts and books in              
          large quantities because he speculated that he would be able to             
          use at least some of those parts and books in those activities.             
          Mr. Thomson did not dispose of any of the aircraft parts and                
          books purchased at auctions that he found unsuitable for use in             
          Aviation’s business activities.                                             
               After the conclusion of film production, the movie studios             
          returned to Aviation the aircraft parts that they had rented from           
          it.  Those parts were often returned to Aviation in a damaged               
          condition and sometimes with pieces missing.  After a movie                 
          studio returned a damaged aircraft part to Aviation, Mr. Thomson            
          sometimes attempted to repair the part in order to make it                  
          suitable to be rented again to a movie studio.  However, after              
          having been subjected to wear and tear from its use by movie                






Page:  Previous  1  2  3  4  5  6  7  8  9  10  Next

Last modified: May 25, 2011