Weller v. Comr., T.C. Memo. 2011-224

(petitioner engaged in high-performance glider activities (providing rides and flight instruction) in a manner that established that the activity was engaged in with an intent to make a profit, but did not substantiate deductions for unreimbursed employee expenses; petitioner did not maintain thorough books and records beyond flight logs, did not prepare budgets or other financial statements, but did review expenses and employed cost-cutting measures; petitioner held himself out as a glider instructor; petitioner not a wealthy individual and incurred substantial expense in acquiring glider and other associated expenses; petitioner worked in aviation field; accuracy-related penalties imposed for the unsubstantiated deductions associated with unreimbursed employee expenses).

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