Leonard Rabinowitz and M. Carole Rabinowitz - Page 23

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               Petitioners charged varying charter rates to different                  
          customers.  Petitioners charged third parties a rate per hour                
          consistent with the price to charter other, similar jets.                    
          Petitioners charged CFI a slightly lower rate, which was the                 
          market rate when a customer booked a large number of flight-hours            
          per year.  These competitive rates were based on an assessment of            
          the rates others charged to charter similar jets.                            
               Petitioners also entered into the arrangement with Ms.                  
          Harrah to accommodate each other on their respective jets if                 
          their own were unavailable.  The arrangement with Ms. Harrah                 
          enabled petitioners to provide services to their third-party                 
          charter customers on a larger jet in the event the Falcon was                
          unavailable and also to use a different jet for personal travel              
          if the Falcon was reserved for paying customers.  In the event               
          petitioners used the Falcon for personal travel, BHJ invoiced                
          petitioners for the travel and petitioners paid for it.  These               
          sums were included in BHJ’s gross receipts.                                  
               Petitioners also made changes to the jet charter activity to            
          try to make it profitable.  Petitioners realized that the initial            
          jet, the Mitsubishi, was not ideal for third-party charters.  The            
          Mitsubishi was not able to fly across the country without                    
          stopping to refuel and was uncomfortable for passengers.                     
          Petitioners decided to trade in the Mitsubishi for the Falcon,               
          which did not have these drawbacks, in the hope that the Falcon              
          would be more attractive to customers and increase petitioners’              
          third-party charter business.                                                





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