Taxpayers who lease or purchase aircraft face a myriad of tax issues, and aircraft can be a favorite target of both federal and state tax auditors. While the restrictions imposed by the “hobby loss” and “passive activity” limitations are more widely known, taxpayers can suffer just as much from a lesser-known scourge: the “at risk” rules imposed by Section 465 of the Internal Revenue Code (the Code).
Non-Recourse Financing Can Imperil Tax Deductions: The Application of the Internal Revenue Code ‘At-Risk’ Rules to Aircraft Purchases
