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Part 135 vs Part 91 is exactly the issue. They thought they were complying with Part 91, those are reasonable rules to run your test flights under I think? Was

• rory096 9y ago
  If they were flying their 'friends and family' all about in 2016-17 in response to bookings on their app without bona fide reasons to go to those places (not least with a student pilot as SIC on business jets), then that's an emphatic yes. The FAA made it quite clear well before then that such flights cannot qualify under Part 91.