- 4 -
petitioner associated himself with Great Lakes Air d/b/a Cirrus
Air Charter (Great Lakes) and Cirrus Flight Operations (Cirrus).
Great Lakes possessed a charter certificate and operated an air
charter business. Cirrus sold fuel and provided maintenance to
small aircraft. During the years in issue, Great Lakes and
Cirrus were owned, in part, by Richard Cross (Cross), who was a
pilot for Sun Country Airlines, and in part by an unrelated
business entity known as General Housewares.
Pursuant to an agreement with Cross, petitioner flew his
aircraft on charter flights under Great Lakes’ charter
certificate. Sometimes, Cirrus would arrange for other pilots to
fly petitioner’s aircraft on charter trips.5
Apparently, petitioner was entitled to receive all the
income generated from flights using his aircraft and was credited
with all the income and charged with associated expenses incurred
by Great Lakes or Cirrus in an account that he maintained with
Great Lakes (Great Lakes account). Romer & Co. provided
accounting services for Great Lakes and Cirrus and prepared their
Federal income tax returns.
5 The record is unclear as to the exact relationship of
these other pilots to Cirrus and to petitioner. One of the
pilots, Richard Matthews, testified that his income from the
flights in question was reported on Forms 1099 issued by Great
Lakes and stated: “I believe we’d be called subcontractors”.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011