From: lawrence delson <=l To: Jeffrey Epstein <[email protected]> Subject: Avioneta Date: Fri, 31 Oct 2014 11:25:33 +0000 As you know, the plane now flies under let's 135 for the potentially beneficial tax treatment and will fly that way unless Leon asks that it fly under 91 or it must fly under 91.1 am still waiting for one good summary of the entire scenario from one of the firms. Yesterday's issue arose and was difficult to clarify in part again because of the number of people involved: beyond Melanie and Leon both Rich and Eileen (and 1) were involved. The recent case below addresses substantiation a Summary by Tax The Tax Court, sustaining accuracy-related penalties, held that a law firm was entitled to some of its travel expense deductions and net operating loss carryforward, finding that the firm could deduct the amounts that it paid to one of the partners' aviation business that had been properly substantiated as business expenses. a Full Text Published by Tax ENGSTROM, LIPSCOMB & LACK, APC, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent UNITED STATES TAX COURT Filed October 20, 2014 Kevin M. Bagley, for petitioner. Monica D. Polo, for respondent. MEMORANDUM FINDINGS OF FACT AND OPINION GOEKE, Judge: Respondent determined deficiencies in Engstrom, Lipscomb & Lack, APC's (petitioner or EL&L) Federal income tax for 2008 through 2010 and accuracy-related penalties under section 6662,1 as follows: [*2] Penalty Year Deficiency sec. 6662(a) 2008 $903,979 $180,796 2009 36,096 7,219 EFTA00999402