Originally Posted by freezingflyboy
That sounds like a tricky proposition. I think you might run into problems if you are providing (ie renting) both the aircraft and the pilot services because you may be seen to take on the qualities of a "commercial operator" in which case you would need an operating certificate. I would talk to an aviation attorney about this one. Is it worth losing a certificate for a few hours of flight time in a C172? I know the FAA has been getting stricter with sight-seeing operators and has been trying to bring them under part 135 or 121 regulation. Be careful with this one.
91 specifically allows you to do the 25NM sightseeing thing, as long as it's point A back to point A. Doesn't matter who supplies the airplane, or if you hold out or not, it's still legal. There are lots of other considerations though: Insurance, 100 hours, etc. If you want to do this, talk to your local FSDO.