Your client, a large construction firm organized as a C corporation, allows certain employees (including the president of the corporation) to use its company owned airplane for non-business flights. The employees include the value of those flights in their income. Your client is uncertain about how to treat the expenses related to these non-business flights. In certain situations the expenses of operating the plane are more than the income imputed to the employees and in certain circumstances the expenses are less. In doing some of their own research, your client found Sutherland Lumber Southwest, Inc. (114 T.C .197 (2000)), which suggests that as long as the employee imputes income, the full amount of the related expenses can be deducted. [The decision in the case was affirmed on appeal, Sutherland Lumber-Southwest, Inc. v. Comm. (2001-2 USTC ¶50,503, 88 AFTR 2d 2001-5026, 255 F.3d 495 (CA-8, 2001)).] Should your client follow the approach in Sutherland?