Leonard Rabinowitz and M. Carole Rabinowitz - Page 12

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          aircraft.  In addition, Mr. Rabinowitz also spent at least 50                
          hours per week on his work for CFI.                                          
          Personal Use of the Jet                                                      
               Petitioners did use the Falcon for some personal travel, but            
          not very often.  Each time petitioners used the Falcon for                   
          personal travel, BHJ billed them and they paid BHJ from their                
          personal checking account.  Petitioners’ accountants verified                
          that an invoice was prepared for personal travel and Mr.                     
          Rabinowitz paid the invoices.  Petitioners’ daughter, Jennifer               
          Heft, who was a merchandising employee of CFI, also made trips in            
          the Falcon to meet with Ms. Little concerning various CFI                    
          matters.  BHJ billed CFI, and CFI paid BHJ, for each of Ms.                  
          Heft’s trips.                                                                
          Arrangement With Verna Harrah                                                
               Verna Harrah (Ms. Harrah), a woman Mr. Rabinowitz was dating            
          from 1990 through 1995 while he was separated from Ms. Little,               
          and who was involved in a movie business with Mr. Rabinowitz,                
          also owned a jet, which cost approximately four times as much as             
          petitioners’ jet.  Ms. Harrah’s jet had nicer amenities and could            
          fly to Europe and South America.  Petitioners agreed with Ms.                
          Harrah that each would look to the other first when they needed              
          to use an aircraft and their own aircraft was busy, and that the             
          rate for the use of the other’s aircraft would be the direct                 
          costs of operation only.  Direct costs of operation were those               
          costs related to the flying time and included a specified amount             
          for wear and tear on the aircraft, fuel, and engine maintenance.             





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