Leonard Rabinowitz and M. Carole Rabinowitz - Page 13

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          Direct costs of operation did not include costs fixed and paid               
          annually, such as insurance, the cost for the hangar, and the                
          salaries of the pilots and mechanics.  Petitioners therefore                 
          charged Ms. Harrah $1,200 per hour for the use of the Falcon                 
          based on the direct costs of operation, and Ms. Harrah charged               
          petitioners approximately $1,300 to $1,400 per hour for the use              
          of her jet based on the direct costs of operation.                           
               Petitioners made sure, however, that Ms. Harrah’s request               
          for use of the Falcon had least priority such that, if a third-              
          party charter customer or CFI had requested the use of the                   
          Falcon, Ms. Harrah would not be able to use it.  Petitioners                 
          believed the arrangement was advantageous to them because the                
          agreement enabled them to use a jet worth about four times as                
          much as their own for only about $100 to $200 more per hour.                 
          Petitioners could use Ms. Harrah’s jet for personal travel or                
          could accommodate charter customers on Ms. Harrah’s jet when the             
          Falcon was not available.                                                    
          Success of the Jet Charter Activity                                          
               Petitioners believed BHJ would be able to generate a profit             
          if the jet had enough hours of flying and if the activity had the            
          right mix of charters to CFI, charters to third parties, and                 
          charters to Ms. Harrah pursuant to their agreement.                          
               CFI was treated like any other customer and did not have                
          priority over using the Falcon.  Petitioners noted that if a                 
          third-party customer wished to book the jet (which would be at a             
          higher rate because of CFI’s bulk discount), petitioners would               





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