From: lawrence delson
To: "jeevacation®gmail.com" <jeevacation®gmail.com>
Subject: Fw: Aircraft guidance for your files
Date: Sat, 07 Jun 2014 13:57:49 +0000
Attachments: NicholsReimbursementFAA20110110-schwab-interp.pdf; AircraftNBAA280F.docx;
Hobby_Loss20111128-moron-hobby-loss.pdf; AirplaneCCA_201210026Section4261.doc
Inline-Images: image001.gif
Jeffrey
Thought you might like to review. Interesting that the hobby loss exposure may be less
than I would have thought.
Larry Delson
Delson International, Inc.
•. BOX 3776
New Yi rk NY 1 t 1
Ort\ a e.
From: "Wiener. Ruth"
To:
Cc:"
Sent: Friday, June 6, 2014 4:51 PM
Subject: Aircraft guidance for your files
Gentlemen: It was a pleasure meeting with you and discussing aircraft ownership and use structuring. In the
quest to shorten the analysis of the myriad issues to get to the best economic end result, I have attached some
guidance for you. I will send you a couple key cases separately, including the Noyce case.
• FAA: Nichols Reimbursement letter allows executive to reimburse under a Part 91 without a
timeshare and in a greater amount than timeshare allows
• Section 280F write up: Relevant only to determine which depreciation schedule to be on, and must
be "passed" to get bonus depreciation. Does not determine how much of the purchase cost is put on to
that schedule —from zero to 100% of the aircraft cost is put on the applicable schedule dependent upon
how much is used in a trade or business (compensatory use counts for that purpose)
• Nice article on the Hobby Loss issue by a fellow member of the tax committee of the NBAA,
discussing Morton ability to aggregate business for that purpose
• Section 4261 excise tax IRS guidance where the IRS attempts to apply the 7.5% tax on the
management fees, calling it a "charter"
Ruth M. Wlmer
Partner
StMcDermott
Will & Emery
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