Former IRS subject matter expert Victoria “Vicki” Boon joins Eric Green to reveal the truth about § 280F and why taxpayers so often stumble when writing off planes, yachts, RVs, and cars. With 22 years inside the IRS, Vicki explains what examiners really look for, the documentation that makes or breaks a case, and the common myths that cost clients big. If you want to bulletproof deductions and avoid audit disasters, this is the episode you can’t miss.
Want to join the webinar on October 16th with Vicki and Eric? Register here: https://taxrepllc.com/20251016-writeoff/
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Planes, Yachts & Automobiles: Cracking IRS § 280F With Victoria Boon
Thanks for joining us on the show. I am joined by one of our trainers, Vicki Boon. It’s very exciting. She left the IRS. We’re recording on your first day of freedom on the light side of the table, we like to think. Vicki was the subject matter expert in §280F and 1031. It’s interesting stuff. She does like-kind exchanges of boats, yachts, RVs, and cars. What can’t you write off? Vicki, thanks for doing this. I’m very excited to have you.
Decoding § 280F: The Depreciation Limit Explained
Thanks for having me. I’ve enjoyed my 22 years at the IRS, almost to the day. I’m excited to branch out and do education and consulting. I’m excited to take the stuff that I learned from the IRS and share it with the public here.
We put up that link. We’re doing a webinar on October 16th, 2025. We already have several hundred people on. It’s going to be a very exciting program. There are a lot of tax pros and, certainly, taxpayers who don’t understand this. I never thought planes and boats were a big thing. It is.
It’s huge.
I’ve had attorneys reach out to me about this program already. There’s a lot of excitement about it. If you don’t mind, for those folks who don’t know what we’re talking about, what is §280F? It’s a code section, but what does §280F do?
§280F is a depreciation limiting section. If you want to take the full benefits of having a boat, a yacht, an RV, or a vehicle, then you need to be able to take the most advantage of the depreciation. There are specific rules in order to meet this, and in order to go and deduct the full amount. That’s what it does. It says, “If you meet this criterion, you have to limit your depreciation.”
There are other code sections that pick up after that that might disallow it even further, but that is what §280F is. It’s a big thing that people trip over and have struggles with. At the IRS, I would help and consult on a lot of the other cases. At least a couple a week, sometimes a couple a day, I would consult on different aircraft.
Towards the end of when I left, they were asking more questions about yachts, RVs, and even vehicles. A lot of times, the vehicles have been overlooked. A high-income initiative, global high wealth, and all of those initiatives have people looking at some of these smaller items. That’s because when they bundle together, they end up being a large deduction.
The Documentation Deep Dive: Proving Business Use To The IRS
Not only are we doing this on the Tax Rep Network on October 16th, 2025, but we’re doing it again a few weeks later on myLawCLE. As it turns out, myLawCLE is out of Miami, where boats and planes are a big deal. I didn’t realize it. The Founder of myLawCLE, John Holloway, when he saw that we were having you, he was like, “I need to have Vicki on our platform. You have no idea how much confusion there is around here.”
He’s part of the boating community down there. I didn’t realize there were clubs and all kinds of online groups. He said, “No one knows what the heck is going on. It’s going to be a very popular program.” It is because, honestly, I’ve not dealt with it myself. I have a client who looks like we’re going to have an issue about the plane, so we may bring you in to consult. You can write off the business use, not the personal use. How do you do that? Is it the logged hours that you’re flying? How do you even start doing that?
Aircraft are a little bit different because they have a few extra rules that aren’t, that don’t apply to other things like boats and vehicles. It comes down to documentation. You document each person, what their use is, what their relationship is, and what they’re doing or what their business purpose is. It comes down to that.
It really comes down to documentation. Once you have that information, you can plug in all the numbers and make all the logistics work. Share on XOnce you have that information, you can plug in all the numbers and make all the little logistics work. It comes down to documentation. Do you have that? Is it contemporaneous? Can it be backed up by something? For example, if you say, “We went to this board meeting,” do you have the minutes for the board meeting, for example? It is things like that that you can do to make that log come to life. The log itself is a starting point. You need to have something beyond that.
For folks tuning in, I’ve had audits for people who do a lot of driving. They’ll have their manual. Having been an auditor, not for the IRS, but I was an internal auditor, what are the other points around that? I’ll ask them, “What were you doing in that area?” They’re like, “We were working on this building.” I’m like, “Do you have the invoices for that building or that address? Did you go to Lowe’s?” In other words, can I start tying in so that an auditor can see?
I’m like, “You’re saying you did all this driving back and forth, like, ‘We were in Connecticut and went to White Plains, New York,’ but I see you went to Lowe’s multiple times over the months. We see invoices for a building in White Plains.” I tell them it’s like the scales of justice. We’re putting as much as we can to tip the scales in our favor. I’m like, “Clearly, you were there for business. You weren’t driving to see a girlfriend in White Plains.” It’s very similar. I’m like, “If you’re using the plane for business, what was the business, and what third-party information around that trip would support that?”
A lot of it with the aircraft comes down to people thinking, “I have the FAA logs, so I’m completely fine.” That’s only the starting point because the FAA logs don’t give any business purpose whatsoever. You can use that as a starting point. That’s exactly what the IRS does. They have a contract, and they can get the FAA logs. That’s great, but you just know how many passengers. You don’t know the passengers’ names. You don’t know their business purpose. They could be a chef, a personal assistant, or anything in between.
Do you mean people try to write off personal stuff for business?
All the time. I’ve seen it all.
I’m stunned.
I even write off trips to go to visit their alma mater, do football games, and do different things like that. If you want to do that, that’s fine, but you can’t necessarily deduct that. It depends on what the primary purpose of the actual trip is and what you are doing.
Avoiding Audit Headaches: Common Mistakes And How To Fix Them
I had an audit a couple of years ago. We were going through stuff, and all of their office expenses were over $1 million. There’s 1 item for $245,000, even. I was like, “What is that?” He rolled up his sleeve and showed me the presidential Rolex with the diamonds, among many things that he was running through his company. His daughter’s wedding ran through one year. I remember thinking, “I know I’m paid to represent you, but I’m rooting for the government here.” People do all kinds of stuff.
Whether it be planes or yachts or anything, the logs are not maintained as well as they could be, and they don't document the business use. Share on XDuring the program, what we’re going to do is break down for folks the way that this should be done and how they can document this properly. It is so that if Uncle Sam does come calling, which is going to be debatable, you know how to handle this. You can go to sleep knowing, “I’ve got everything in place, so I can support.” You don’t have to worry about the return.
Mostly, I’m interested in dispelling a lot of the myths around this stuff. You talk to accountants and they’re like, “Allocate the hours, and it’ll be fine.” I’m like, “I’m not not sure that’s the way it works.” Are there certain specific issues you’ve seen come up again and again? Let’s take boats, for example. Is there one specific thing that you could point to that people seem to get wrong?
A lot of it has to do with the logs. They don’t keep the logs. The logs don’t prove the business use. They are lacking in substantiation. You go to the log and say, “I went to this,” or, “We held a party here,” or, “We did that.” Show me the invites. Show me emails. Show me something that’s contemporaneous. Show me a calendar. Show me something else that backs that up. The biggest thing with any of these, whether it be planes, yachts, or anything, is the logs. They’re not maintained as well as they could be, and they don’t document the business use. If you use it for business, document it.
For aircraft, one thing that you could do is use it for personal use. That’s fine. Do a SIFL calculation and pick up a little bit of income. You still get a deduction. There are ways that you can do things. Aircraft are special. There are specific rules for that, but there are ways that you can still get that full deduction. It comes down to documentation.
It’s not just each trip. It’s each person on each trip. What’s their relationship? Did they go on it? Did you happen to bring some family members? Are the family members employees? Are they not employees? Did you bring your girlfriend? Did you bring fill-in-the-blank? Who are these people? What do they do? What’s their relationship? That’s the biggest area right there. If I could sum it all up in one thing, it would be documentation.
I get that. I have questions about cars and RVs. With automobiles, I would think auto should be pretty cut and dry, aside from the mileage log that people don’t like to keep. There are all kinds of apps that do this. I think the QuickBooks app, maybe?
There are a lot of different apps that do it. When you have a log, you can back that up with, “I had an oil change. Now, I have the mileage on my oil change receipt. That backs up and proves my log is correct.” If you have that documentation sometime around the beginning of the year or the end of the year, you can show, “Here’s this.” A lot of those car repair shops, when they do all the different services on your car, log it in, and it goes to Carfax. You can get a Carfax report on it, and it’ll show, “Here’s the mileage on this date.” There are different ways that you can go back and try to recreate some of those mileage logs, too.
IRS Audits: Understanding The Taxpayer’s Burden Of Proof
I don’t keep a mileage log data date, but I have a calendar, so I can see where I was. I have Google Maps, MapQuest, or one of those. It’s the third step beyond that. For example, I drove here. What was the business purpose? Is there anything around that that would also support that there was a business purpose? Does the IRS get the Carfax reports? Do they have access to that?
I don’t think so. It’s something that they might be able to pull down, but it’s as easy for the person to pull it down. The IRS isn’t going to look for your substantiation. They’re going to tell you, “If you want the deduction, you’ve got to substantiate it.” They’re not going to go looking for it. They will get things like the FAA logs. That’s something that they will get because then, they can say, “Make sure that all of the flights are accounted for.” They can say, “These are all the flights. The flights matched up with the FAA. We’re good to go.” We’re not worrying about additional use that’s not documented somewhere.
My thought would be to get the Carfax report when they see how many people have claimed to try to show them, “We can look at the miles.” We’re going to appeals, but I had an audit. The accountant handling it took the position that it’s the government’s problem to prove. They didn’t cooperate with the auditor and provided almost nothing. They then called us and said, “Tax court case. We are going to need you to file in tax court.”
The moment you see the report and everything’s been disallowed, I’m like, “There was clearly a breakdown here. Either they are fraudsters who made everything up, or something happened.” I asked, and he said, “They kept asking for stuff. It’s your problem. You’re the government. You’re doing the audit. You do it.” I had to explain to them, “That’s not true. The burden is on the taxpayer to prove that they’re entitled to the deduction. We’re going to get them filed in tax court, and it’ll get sent to appeals. When it gets to appeals, the burden’s on you. We’re going to have to produce all this anyway. What the heck were you thinking?” The burden is on the taxpayer.
For deductions. For income, the burden is on the IRS.
For instance, the IRS takes the bank statements and adds up all the deposits. That’s income. The burden I’ll shift to the taxpayer is to prove that it’s not taxable. What I was thinking about was the instance where the taxpayer didn’t have copies of the FAA logs. I asked the examiner, “Can you get them?” I’ve had them agree to summon stuff.
We had a bank that merged, and my client didn’t have the bank statements. They went online, and they couldn’t get them online anymore. They went into the bank, and the bank claimed that it was on microfiche and they didn’t know where it was. Wells Fargo had bought one of these other banks. Remember when all those mergers were going on in the early 2000s? It was that. We asked the auditor, and the auditor said, “I’ll summon them.” They summoned them, and they got the records. They gave us copies of it, and we got through the audit.
They can go through and summon those types of records. The FAA records don’t need a summons. They need to have requested them from the taxpayer. Once they do, they have an agreement, and they can pull them down. Pretty much anyone can go and access a lot of the FAA information. It’s public information at that point.
Connect With Vicki Boone: Expert Tax Consulting
I’m very excited for our program on the 16th. Out of curiosity, if folks want to get a hold of you because they have an audit going on or they have a client and they want to consult with you, what is the best way to get a hold of you?
I’ve joined my husband’s consulting business. The easiest way to get in touch with me is Victoria@Boon.Tax, or you can go to Boon.Tax and look up our company and the different representations that we do there.
Thanks for doing this. I’m looking forward to the 16th. For the people reading, you can go register for this. You’re going to learn everything you need to know about §280F, or at the very least, you’re going to have a good understanding of how this works. If you need to or want to reach out to Vicki, please do so. Twenty-two years of expertise from the IRS is hugely helpful. I have that plane client I may be talking to you about, and John has the boat stuff. Vicki’s going to be in high demand. Thanks, everyone, for tuning in. Vicki, thank you. I’m looking forward to the webinar on the 16th.
I’m looking forward to it as well.
Thank you.
Important Links
- Vicki Boon
- Victoria@Boon.Tax
- Planes, Yachts, Automobiles, and RVs: How to Write-Off Listed Property Under IRC §280F Webinar
About Vicki Boon
Victoria Boon – Former IRS Subject Matter Expert
I’m a seasoned tax consultant and federal tax authority with 20+ years of experience at the IRS, most recently serving as a Subject Matter Expert for Large Business & International (LB&I). I specialize in audit defense strategies, technical training, and policy guidance in areas such as IRC 1031 (like-kind) exchanges, IRC 274 (meals & entertainment), IRC 280F Listed Property (aircraft, yachts, RVs, and vehicles).
I’ve assisted in updating IRS publications (544, 551 and 946) as well as IRS forms (8824), led national CPE trainings, and supported complex compliance campaigns for business aircraft and conservation easements. I’m now bringing this experience to the private sector through consulting and customized training for tax professionals, attorneys, real estate agents and business advisors.
