Nicholas M. Romer - Page 14




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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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