- 3 - Gulfstream). During 1996, the Gulfstream was used partly in pursuit of NBA’s trade or business for transportation purposes and partly for personal entertainment use by certain employees (the employees) of NBA.4 The net expenditures, including depreciation, incurred by Aviation during the taxable year 1996 in connection with the operation and ownership of the Gulfstream totaled $2,548,990. On the basis of an allocation according to flight miles, $1,814,894, or approximately 71.2 percent, of the net expenditures was attributed to business use. The remaining portion, $734,096, or approximately 28.8 percent, was attributed to personal entertainment use. Petitioner deducted the entire $2,548,990 related to the operation and ownership of the Gulfstream on its 1996 Federal income tax return. The personal entertainment use of the Gulfstream was treated as fringe benefit compensation to the recipient employees. On the basis of the valuation rules set forth in section 1.61-21(g), Income Tax Regs., NBA determinated that the value of the fringe benefits received by the employees on account of the personal entertainment use of the Gulfstream totaled $131,575 for the taxable year 1996. The amount of the fringe benefits attributable to each employee was included on the employees’ respective Forms W-2, Wage and Tax Statement. The $2,548,990 4The personal entertainment use consisted of hunting, fishing, vacation, and other similar trips for certain employees of NBA.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011