Leonard Rabinowitz and M. Carole Rabinowitz - Page 15

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               Petitioners suffered a net loss for each year from 1985                 
          through 1997 attributable to their jet charter activity.  During             
          the relevant years, BHJ had the following gross income, net loss             
          and net cash flow:                                                           
                              Net Income                                               
               Year     Gross Income          (Loss)      Net Cash Flow                
               1993   $580,340          ($743,485)      ($547,984)                     
               1994   545,941           (685,719)     (485,423)                        
               1995   447,524           (775,618)     (574,585)                        
               1996   527,298           (521,076)     (397,924)                        
               1997   273,704           (214,126)     (208,938)                        
          Repairs and maintenance were the major expenses during the                   
          relevant years.                                                              
               Mr. Rabinowitz was constantly trying to improve the jet                 
          charter activity and remained focused on increasing the bottom               
          line of the combined entities.  Although BHJ did not generate a              
          profit, Mr. Rabinowitz was pleased with the jet charter activity             
          because of the benefits to CFI.  Mr. Rabinowitz continued trying             
          to improve BHJ’s operations as well.                                         
          Sale of CFI and Termination of the Jet Charter Activity                      
               In April 1997, petitioners decided to sell the Falcon for               
          $4.35 million and terminated their jet charter activity.                     
          Petitioners also decided to sell CFI.  They ultimately sold it to            
          a larger company in August 2000 in exchange for stock.                       
          Deductions at Issue                                                          
               Petitioners filed joint tax returns for each of the relevant            
          years and deducted losses attributable to the jet charter                    




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