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©
1998 By Michael P. Fleming
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Issue
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Corp.
Family
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Time
Sharing
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Inter
-change
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Dry
Leasing
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Co-Owner-
ship
|
Joint
Owner-
ship
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Fractional
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Manag-
ement
|
Charter
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Usage
Profile
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Liberal
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Occasional
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Liberal
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Liberal
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Liberal
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Liberal
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100-200
hours
|
Liberal
|
Liberal
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Operating
Flexibility
|
Part
91
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Part
91
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Part
91
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Part
91
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Part
91
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Part
91
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Part
91, evolving
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Part
91
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Part
135
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Acquisition
Expense
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No
impact
|
No
impact
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No
impact
|
No
impact
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Reduced
|
Reduced
|
Reduced
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No
impact
|
None
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Cost
Recovery
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Fully-
Allocated
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2
times
fuel
|
Swap
plus Adjust.
|
Liberal
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Apportioned
|
Fully-
Allocated
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N/A
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N/A
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Profit
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Ownership
Form
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Own/lease
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Own/lease
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Swap
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Own/lease
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Split
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Split
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Split/Swap
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Own/lease
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None
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Citizenship
Issue
|
Registration
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DOT
Licensing
|
DOT
Licensing
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No
Issue
|
Registration
|
Registration,
DOT
|
Registration,
DOT
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No
Impact
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None
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FET
Applicability
|
80%
Rule
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Applies
|
Applies
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None
|
None
|
None
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Applies
|
Usually
No Impact
|
Applies
|
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State
Sales/Use
|
Normal
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Lease
Tax?
|
Lease
Tax?
|
Lease
Tax?
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Normal
|
Normal
|
Special
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Normal
|
Maybe
Reduced
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Depreciation
Issues
|
Normal
|
Normal
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Normal
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Normal
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Split
|
Split
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Split
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Normal
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7-year
schedule
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Passive
Loss
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Normal
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Rental
Activity
|
Rental
Activity
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Rental,
passive
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Normal
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Normal
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Normal
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Tends
to be Passive
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Normal
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Demo
Flights
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N/A
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Yes,
or use
91.501(b)(3)
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Possible
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Possible
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N/A
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N/A
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N/A
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N/A
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Liberal
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Liability/
Insurance
|
Additional
Insureds
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Additional
Insureds
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Non-owned
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Lease
cover
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Split
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Split
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Fleet
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Normal
or Fleet
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Fleet
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Disclosure
Issues
|
<
FMV
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Legal
Cap
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N/A
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<
FMV
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N/A
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N/A
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N/A
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N/A
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<
FMV
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 |
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Read Articles by
J. Mesinger
as printed in
World Aircraft Sales
Magazine
|