- 4 - 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-Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011