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Maryland
On May 24, 1987, Newman moved the yacht from Lighthouse
Point to Mears Great Oak Landing, which is in Maryland and on the
Chesapeake Bay. He returned the yacht to Lighthouse Point on
October 5, 1987.
Mears Great Oak Landing is 2-1/2-hours travel time, by car,
from petitioner’s home in Philadelphia.
Petitioner arranged with an individual, David Hart (Hart) to
maintain and keep up the yacht while it was at Mears Great Oak
Landing. Hart was to try and obtain charters. At Mears Great
Oak Landing there was a meeting center with approximately
30 rooms and a 9-hole golf course. The yacht was the only yacht
for charter at Mears Great Oak Landing. The meeting director at
Mears Great Oak Landing, and possibly other meeting center
personnel, also were asked to try and obtain charters.
Except for use made by petitioner of the yacht, there were
no charters of the yacht during the time it was at Mears Great
Oak Landing. Petitioner made substantial use of the yacht on
weekends. Petitioner paid for his use of the yacht in 1988.
Florida
After the yacht was returned to Florida in October 1987, no
use of it was made by anyone other than petitioner.
Trade-In of the Yacht and Termination of Charter Business
In January 1988, Ballard Marine disposed of the yacht in a
transaction whereby it acquired another boat, a 56-foot Hatteras
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