In that case, the taxpayer had used the special SIFL
valuation rules applicable to flights on noncommercial aircraft under Treas.
The use of SIFL
valuation guidelines was announced in some detail in a Senate Finance Committee report (152) accompanying 1985 legislation principally concerned with eliminating a requirement of contemporaneous recordkeeping of business automobile usage.
System is a key component in conjunction with the CSRV engines when they are being fueled by natural and landfill gaseous fuels.
The Tax Court further held that the fact that the SIFL
amount may be substantially less than the offsetting deduction is irrelevant and that taxpayers may take as a deduction the full cost of allowing their executives to use corporate aircraft for personal purposes.
61-21(g) (known as the Standard Industry Fare Level or SIFL
rules) to determine the value of the executives' entertainment trips.
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Thus, the mismatch of income inclusion versus deductible expense previously enjoyed by taxpayers using SIFL
to value personal use may be a thing of the past.
In virtually every instance involving the use of corporate jets, this working condition fringe safe harbor for security-related travel reduces the valuation of personal trips on the corporate jet from 400 percent of the SIFL
rates to 200 percent.
In general, the value of personal flights taxable to employees using SIFL
does not correspond with the employer's actual costs of providing the flights.
14) The SIFL
rate is multiplied by an "aircraft multiple" based on an airplane's weight and whether the employee is classified as a control employee, or a non-control employee, and a terminal charge is added.
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Under the new standards for using the special valuation rules, if this reporting error were ever discovered on audit, the amount of the adjustment in imputable but unreported income would be limited to the SIFL
rate for a non-control employee (which is far less than the charter value of the flight).