- 4 - Neppach had no “financial equity” in the corporation at that time. Petitioner used personal retirement funds and commercial loans to make the equipment purchases. In 1997, petitioner purchased an airplane at a cost of $38,000 in order to lease it to PFC. This plane subsequently was sold in 1998 for $48,000, at a gain of $17,600. In 1998, petitioner purchased two airplanes and two airplane engines for lease to PFC. The cost of the airplanes totaled $279,000, and the cost of the engines totaled $60,000. Written leases were executed between petitioner and PFC under which PFC was responsible for operating and maintenance expenses, including fuel, repairs, insurance, and taxes. Payments required under the leases ranged from $1,000 per month to $2,000 per month per aircraft. PFC made actual lease payments to petitioner of $7,000 in 1997, $9,500 in 1998, and $34,940 in 1999. These payments were significantly less than what was required under the leases; for example, the leases required payments totaling $40,100 in 1998. The equipment leased to PFC was used exclusively by PFC. In addition to the aircraft leased to PFC by petitioner and the five aircraft acquired from Stensin Aviation, PFC leased five more aircraft from other parties. On PFC’s Federal income tax returns for the years in issue, the following income was reported and deductions claimed:Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011