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aviation activities. Petitioner admitted at trial that he used
Romer & Co.’s checking account to pay his personal expenses.
Thus, the evidence does not rule out the possibility that
petitioner made the checks at issue payable to Sheffers to cover
personal expenses. Petitioner has failed to substantiate
business purpose for these payments.
6. Pilot Expenses
Petitioner contends that pilots who flew his aircraft
generally charged their expenses to his credit card. He also
contends that he reimbursed one pilot named Adrian Grimm (Grimm)
$2,010 by paying that amount directly to Grimm’s creditors.
Petitioner claims he is entitled to deduct the $2,010 as a
business expense under section 162.
In support of his claim, petitioner introduced into evidence
five checks made payable to parties that petitioner contends were
Grimm’s creditors. While the checks themselves make no mention
of Grimm, the notations in petitioner’s check register contain
such statements as “Adrian Grimm-Fuel & Expense”, “for Adrian”,
or just “Adrian”.
Petitioner has failed adequately to establish that the
payments in question were for pilot services rendered.
7. Rent
Petitioner seeks a deduction for a check in the amount of
$200 for hangar rent for June 1989. On the basis of the
documentary evidence in the record, we conclude that petitioner
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