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lack of profit motive where the taxpayer employs competent and
qualified persons to carry on the activity. Id.
Mr. Rabinowitz spent approximately 30 hours per week on the
jet charter activity during the relevant years. This time was in
addition to the approximately 50 hours per week Mr. Rabinowitz
spent on CFI’s business. Mr. Rabinowitz was involved in every
aspect of operating the jet charter business, from approving
flight logs, generating and approving invoices, marketing the
charter service, addressing employee and compensation matters,
and generally managing the aircraft. Petitioners also hired
three full-time employees to work for the jet charter activity
who included a chief pilot, a co-captain, and a mechanic. The
two bookkeepers also together spent approximately full time on
the jet charter activity.
Taken together, Mr. Rabinowitz and BHJ’s employees spent a
considerable amount of time and effort on the jet charter
activity during the relevant years. That Mr. Rabinowitz spent so
much time on the jet charter activity in addition to his
considerable responsibilities for CFI indicates that he did not
take the jet charter activity lightly. He made a large effort on
the jet charter activity in addition to his numerous
responsibilities for CFI. These facts support petitioners’
contention that they operated the jet charter activity for
profit.
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