The National Business Aviation Association (NBAA) submitted a letter to the IRS recommending guidance on the treatment of leasing activity under I.R.C. § 280F(b). The letter argues against the interpretation in TAM 200945037 that deems all flights on leased aircraft to 5-percent owners or related parties as non-business use. NBAA requests that the IRS consider the lessee's actual use of the aircraft to determine qualified business use.
documents/EFTA00602757.pdf
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