- 28 -
Petitioner alleges that he used space in his home for, among
other things, storing supplies, parts, and materials, flight
planning, business planning, purchasing aircraft parts, and
searching for aircraft sales. The only proof petitioner presents
to evidence these allegations consists of his self-serving and
uncorroborated testimony. For the reasons discussed supra, we do
not accept his testimony. See Tokarski v. Commissioner, supra at
77; Shackelford v. Commissioner, supra.
Comparing the time that petitioner spent at home with the
amount of time he spent at other places where aviation-related
activities occurred supports a determination that petitioner’s
home was not his principal place of business. See Fryer v.
Commissioner, T.C. Memo. 1974-77. Nothing in the record suggests
that the amount of time petitioner spent engaged in aviation-
related activities at home was significant in relation to the
amount of time he spent at other business locations where
aviation-related activities occurred. For example, from
petitioner’s testimony at trial, we understand that a large part
of his work as an aircraft dealer involved travel away from his
home. Thus, without more, we cannot say that petitioner spent
more time at his home office on aircraft sales than he did
traveling. See Commissioner v. Soliman, supra at 175-176; Beale
v. Commissioner, T.C. Memo. 2000-158.
Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 NextLast modified: May 25, 2011