And he could time his fractional gifts so they'd all be deductible the year he made them, or the next five years (gifts of appreciated property can reduce your gross income by only 30% a year).
Last year, the Internal Revenue Service ruled that an unnamed private S corporation could deduct the full cost of owning two fractional shares in jets, even though those planes were used just 5% of the time for business.
These are either licensed resellers of unused fractional shares, or they are charter brokers who make arrangements with charter companies who sell blocks of time to them, at a discounted rate.