Jon R. Ecker - Page 3




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               Respondent determined a deficiency of $3,940 in petitioner’s           
          Federal income tax for 1996.  Petitioner conceded that he is not            
          entitled to a deduction for education expenses relating to his              
          wife.  Thus, we must decide whether the expense incurred for                
          pilot training is deductible from petitioners’ gross income under           
          section 162.  We hold that it is.                                           
                                     Background                                       
               The stipulation of facts and the accompanying exhibits are             
          incorporated herein by reference.  Petitioner resided in                    
          Kingwood, Texas, at the time the petition in this case was filed.           
               In the 1980s, petitioner served in the U.S. military.                  
          Petitioner retired from the service in 1991.  While in the                  
          service he trained on and was certified to fly helicopters.  He             
          served as a helicopter test pilot.  Petitioner also flew and was            
          familiar with the systems and operations of a U-21 aircraft, a              
          military version of the Beech 1900D, a fixed-wing aircraft.                 
               In 1984, petitioner received the Federal Aviation                      
          Administration’s (FAA) certified fixed-wing private rating,                 
          allowing him to fly a small single-engine aircraft such as a                
          Cessna or a Piper.  When petitioner left the service it was                 
          difficult to secure employment as a pilot because the number of             
          pilots exceeded the number of positions available.  As a result,            
          petitioner sought to increase his FAA fixed-wing rating through             
          more classes and flight time.  On March 16, 1992, petitioner                






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