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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
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Last modified: May 25, 2011