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CORNFELD v. C.I.R.

No. 85-1243.

797 F.2d 1049 (1986)

Bernard CORNFELD, Appellant, v. COMMISSIONER OF INTERNAL REVENUE, Appellee.

United States Court of Appeals, District of Columbia Circuit.

Decided August 12, 1986.

Attorney(s) appearing for the Case

Bernard Cornfeld, pro se. Burton W. Kanter, New York City, and Harold J. Lipsitz, were on brief, for appellant.

Richard J. Driscoll, Atty., Dept. of Justice, with whom Glenn L. Archer, Jr., Asst. Atty. Gen., Michael L. Paup and Ann Belanger Durney, Attys., Dept. of Justice, Washington, D.C., were on brief, for appellee.

Before WALD, EDWARDS and KOZINSKI, Circuit Judges.

KOZINSKI, Circuit Judge:

In this appeal from a judgment of the Tax Court we consider whether taxpayer is entitled to a business deduction attributable to ownership of a BAC 1-11 passenger jet aircraft.

FACTS

For a number of years during the 1950's and 60's taxpayer Bernard Cornfeld was a successful entrepreneur and businessman. In 1969 he was the principal shareholder, president and chairman of the board of Investor Overseas Services, Ltd (S.A.)...

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