Winston Knauss - Page 8

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          Winston was $1,200,000.  Adjusted basis reported on the return,             
          as a result of a claim of $33,360 in depreciation, was                      
          $1,166,640, resulting in a reported gain of $83,360 on the sale             
          of the vessel.  Accepting petitioner’s claimed depreciation,                
          respondent nonetheless determined that petitioner’s adjusted                
          basis in the vessel at the time of sale was $639,566, or $527,074           
          less than claimed by petitioner, resulting in a determination of            
          unreported gain in that amount.                                             
               Sir Winston II                                                         
               On December 5, 1994, petitioner entered into a fixed-price             
          contract with Marine Builders, Inc., to build a yacht to his                
          specifications for $1,099,173.  Petitioner made cash payments               
          totaling $39,000 toward the construction of the yacht.                      
          Petitioner also made direct payments to vendors totaling $33,330            
          for improvements to the yacht during its construction.  The yacht           
          was issued a certificate of inspection by the U.S. Coast Guard              
          and assigned identification No. D1037815.  The yacht was                    
          delivered complete and ready to carry passengers for hire on                
          January 11, 1996.  Petitioner also named this vessel the Sir                
          Winston (Sir Winston II).                                                   
               During the 1-year period after petitioner took delivery of             
          the Sir Winston II (January 11, 1996 to January 11, 1997),                  
          petitioner had two checking accounts and a brokerage account on             
          which he could draw checks.  During this period, the checks drawn           






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