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transportation and communication efficiencies provided by the
partnership airplane. In addition, the Court of Appeals found
that losses were due, in large part, to the dramatic rise in the
cost of fuel, inflation, and increased interest rates occurring
during the late 1970s and early 1980s. The Court of Appeals
concluded that profits generated by the corporation through the
use of the partnership’s plane justified a conclusion that the
partnership venture was an activity engaged in for profit.
In contrast to the taxpayer in Campbell, petitioner has not
proven even an incidental benefit to his commodities trading
business or any other business resulting from BAC’s activities.
Petitioner testified that his unparalleled trading success was
due to his relationships with other traders and brokers in the
pit and that his discussions with traders and brokers on the
plane trips to and from Granot Loma enabled him to build close
personal relationships with the brokers and traders. However,
the objective facts in the record demonstrate that after
petitioner purchased the King Air and organized BAC in 1988,
petitioner’s income from his commodities trading business
steadily decreased.
Also unlike the situation in Campbell, where the plane
leasing partnership was conducted solely to benefit another
business and was wholly dependent upon that business, BAC was
conducted almost exclusively to benefit petitioner personally. A
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