- 23 - 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 petitionerPage: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Next
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