- 4 - would be forthcoming and willing to pay a large enough daily charter fee so that he would break even on his investment with the boat being chartered only 3 to 5 days a month. Petitioner made his Federal income tax returns for 1986 and 1987 on the basis of a calender year. Ballard Marine Ballard Marine, a Maine corporation, was organized on September 2, 1986. The articles of incorporation of Ballard Marine fail to state any purpose for which the corporation was organized. Petitioner was the sole initial director of the corporation. The initial officers of Ballard Marine were a president and a treasurer. Petitioner was appointed to both offices. Ballard Marine elected to be an S corporation within the meaning of section 1361(a). Ballard Marine’s election to be an S corporation was effective for its first taxable year. Ballard Marine is a calender year taxpayer. By contract dated October 17, 1986, Ballard Marine purchased a 49-foot, MY MK III Gulfstar motor yacht (the yacht) for a total contract price of $300,000. Ballard Marine also paid a Florida sales tax of $15,000. Ballard Marine financed $175,000 of the purchase price of the yacht with a bank loan. The yacht was delivered to Ballard Marine on October 23, 1986, in Annapolis, Maryland. In connection with Ballard Marine’s purchase of the yacht, Ballard Marine, or petitioner, consulted with legal counsel.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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