Noyce v. Commissioner
United States Tax Court
97 T.C. 670 (1991)
- Written by Kelsey Libby, JD
Facts
Noyce (plaintiff) was the founder of Intel Corporation and served as its vice chairman. In 1983, Noyce earned $105,076 in compensation, and his holdings were worth $60 million. As vice chairman, Noyce oversaw Intel’s government and public relations and served on numerous boards and associations to advance Intel’s interests, including at the University of California and Grinnell College. Noyce traveled frequently and extensively throughout the country. In April 1983, Noyce purchased an aircraft for $1,260,000, and he used it exclusively for Intel business. The cost of operating Noyce’s aircraft was less than flying on commercial charter flights, and the aircraft afforded him better flexibility to maximize appearances and reduce travel time. Intel had a written travel-reimbursement policy that required officers to personally cover certain business-related expenses, including any air-travel expenses exceeding the cost of coach airfare. On his 1983 tax return, Noyce deducted a total of $139,369 in connection with the aircraft, consisting of both operating expenses and depreciation. The commissioner of internal revenue (defendant) disallowed the deductions.
Rule of Law
Issue
Holding and Reasoning (Ruwe, J.)
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