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Airplane-Related Expenses Not Associated with Trade or Business,

and Tax Deductions Were Disallowed In US Tax Court Case

  Courtesy of http://tax.cchgroup.com

January, 2009. An individual taxpayer could not deduct expenses associated with his ownership of an airplane on Schedule C because none of the activities related to the airplane was a trade or business. The individual was not involved in the trade or business of environmental consulting in one of the years at issue because he did not establish that he engaged in related activities with the required continuity and regularity. Furthermore, expenses incurred by the individual with respect to aircraft maintenance activity in one year and in environmental aviation activity in the subsequent year were not deductible. The individual was not engaged in either activity as a trade or business because his primary purpose for engaging in the activities was not income or profit. His recordkeeping was disorganized and unreliable, he could not have an expectation that assets used in the activity would appreciate, he could not have had a good-faith expectation of realizing a profit on his operation, he introduced no evidence regarding the financial performance of his aircraft maintenance activity for previous years or evidence regarding occasional profits, and the individual's full-time job allowed the individual to conduct the aircraft maintenance activity at a loss. Thus, the individual's allowable deductions were limited under Code Sec. 183(b)(2) to his gross income from the activity.

  The Code Sec. 6662(b)(2) accuracy-related penalty was imposed with respect to both years at issue. The taxpayer did not contend that he was not negligent, that he had reasonable cause or that he acted in good faith.

R.L. Rowden, TC Memo. 2009-41, Dec. 57,744(M)

Guernsey-UK-Tax-Exchange

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