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As to the claimed cash purchases of fuel, petitioner has no
receipts to support his expenditures. Petitioner attempts to
fill this evidentiary void by the following methodology: First,
petitioner uses his flight logbooks for each of the subject years
to obtain the total hours that he alleges were flown in each of
his aircraft. Next, petitioner postulates the number of gallons
each aircraft consumed per hour of flight to estimate the total
number of gallons of fuel each of his aircraft consumed each
year, based on the hours he claims the aircraft were flown.
Then, to arrive at his total fuel expenses for each year,
petitioner postulates the average cost of a gallon of aviation
fuel for the years in question and multiplies that figure by the
number of gallons he estimates each aircraft to have consumed.
Finally, petitioner subtracts from the total fuel expenses for
each year the amount of fuel expenditures he has documentation
for and arrives at the amount he says he must have purchased with
cash in each year.
We find petitioner’s methodology deficient in practically
every respect. In particular, petitioner has failed to
corroborate his self-serving testimony with any competent proof
as to the fuel efficiency of his aircraft or the cost of aviation
fuel during the relevant time periods. Indeed, petitioner’s
testimony leaves us unpersuaded that he actually incurred the
cash expenditures.
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