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Your client, a large construction firm organized as a C corporation allows certain employees (including the president of the corporation) to use its company owned

Your client, a large construction firm organized as a C corporation allows certain employees (including the president of the corporation) to use its company owned airplane for nonbusiness flights. The employees include the value of the flights in thier income. Your client is uncertain about how to treat the expenses related to the 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 Southerland Lumber-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. Should your client follow the approach in Sutherland?

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