Question
Need help?thanks. Your client, a large construction firm organized as a C corporation, allows certain employees (including the president of the corporation) to use its
Need help?thanks.
Your client, a large construction firm organized as a C corporation, allows certain employees (including the president of the corporation) to use its com- pany-owned airplane for nonbusiness flights. The employees include the value of the flights in their income. Your client is uncertain about how to treat the expenses related to these nonbusiness flights. In certain situations, the expenses of operating the plane are more than the income imputed to the employees, and in certain circumstances, the expenses are less. In doing some of its own research, your client found Sutherland Lum- ber-Southwest, Inc. [114 T.C. 197 (2000)], which suggests that as long as the employee imputes income, the full amount of the related expenses can be deducted. [The decision in the case was affirmed on appeal, Sutherland Lumber-Southwest, Inc. v. Comm., 20012 USTC {50,503, 88 AFTR 2d 20015026, 255 F.3d 495 (CA8, 2001).] Should your client follow the approach in Sutherland? Explain.
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