Ralph E. Wesinger, Jr. and Catherine R. Wesinger - Page 8




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               One further item bearing upon petitioners’ income and                  
          finances for the contested years was the rental of a personal               
          aircraft.  Petitioner owned a 1979 Turbo Dakota plane.  This                
          aircraft was both flown by petitioner for his personal use and              
          rented to SRMC for business use.  Petitioner kept a handwritten             
          log of flight times, which indicated the number of hours flown              
          and the purpose of the usage.  In 1992 and 1993, the years as to            
          which respondent disallowed plane losses, trips labeled business            
          accounted for an approximate 17 to 22 percent of the total usage.           
          Travel related to the ranch ranged between three-fourths and two-           
          thirds of the total hours.  The remaining time was apparently               
          devoted to other personal use, as no evidence was presented of              
          rentals, or attempts to rent, to additional third parties.                  
               Petitioner charged SRMC an hourly lease rate when the                  
          company utilized the plane for traveling to customer premises.              
          He set the price by calling local businesses that rent aircraft             
          and inquiring what they charged for similar machines.  He then              
          established a price consistent with the local market.  Using this           
          practice, petitioner’s aircraft-rental operations reported losses           
          in 1990, 1992, 1993, and 1997.  Profits were generated in 1991,             
          1994, 1995, and 1996.                                                       
               The overall financial impact of the circumstances related              
          above is summarized in the following table.  The ranch losses               
          deducted for 1992 through 1995, the years at issue, totaled                 






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