Eugene J. and Kathryn A. Schumacher - Page 5

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          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:                   








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