Accordingly, we hold that the attempt to charter the sailboat was an activity "not engaged in for profit" within the meaning of section 183. Hence, it is not necessary to discuss the section 1366(d)(1) loss requirements regarding S corporations. B. Fishing Boat Activity In 1985, Mr. Hilliard became aware of a boat investment opportunity through his accountant, Nathaniel Brazil. Mr. Brazil, who was married to Mr. Hilliard's cousin, was also a friend and has been petitioners' accountant since 1968. Pursuant to Mr. Brazil's proposal, petitioners were to purchase a boat and place it in a charter activity in Florida using Inter Island Charters, Inc. Petitioners did not do any independent investigation and relied on Mr. Brazil for investigation of the fishing boat investment. There is no indication that Mr. Brazil traveled to Florida to investigate the fishing boat. On Mr. Brazil's advice, petitioners agreed to a $199,894 purchase price for a new 1985 Sport Strike Fisherman boat named "My Toy" (fishing boat) during March or April 1985; the boat was to be docked in Fort Lauderdale, Florida. Mr. Hilliard did not know whether Mr. Brazil had any experience concerning investments in boat chartering. Early in March 1985, Mr. Hilliard executed a purchase order for a fishing boat that he had not seen prior to making the order. Mr. Brazil had arranged for petitioners to meet with thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011