Mark and Helen Thomson - Page 4




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          studios, an aircraft part deteriorated over time, which varied              
          depending on the particular aircraft part and its treatment by              
          the movie studios during rental.                                            
               During the years at issue, petitioner stored many of the               
          aircraft parts that he acquired outdoors on land that he owned in           
          the desert (desert property).  Exposure to the weather also                 
          caused some of those parts to deteriorate and become useless to             
          Aviation’s business activities.  Mr. Thomson did not dispose of             
          any of those deteriorated aircraft parts.  Instead, he retained             
          them, together with the aircraft parts that he was holding for              
          rental, on his desert property.                                             
               During the years at issue, Mr. Thomson did not maintain any            
          records showing (1) the specific aircraft parts rented by Avia-             
          tion to the movie studios, (2) when the aircraft parts were                 
          returned by those movie studios, and (3) whether or not the                 
          aircraft parts that were rented needed to be replaced or repaired           
          after those movie studios returned them to Aviation.                        
               Petitioners filed Form 1040, U.S. Individual Income Tax                
          Return, for each of the years 1993 and 1994.  Petitioners re-               
          ported certain income and claimed certain expenses from Avia-               
          tion's business activities in Schedule C of Form 1040 (Schedule             
          C) for each of those years.                                                 
                                       OPINION                                        
               Petitioners bear the burden of proving that the determina-             






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