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1983 1984 1985
Gross income $3,250 $5,680 $6,400
Expenses:
Advertising --- 77 ---
Car & truck --- --- 1,680
Depreciation 11,974 18,579 19,186
Insurance 846 1,083 2,055
Interest 3,860 10,843 11,745
Repairs 3,432 462 ---
Supplies 800 1,368 ---
Taxes 857 701 1,391
Travel & ent. 176 1,104 ---
Fuel 175 134 ---
Boat survey 176 --- ---
Berth rental 1,631 2,450 2,445
Amortization 34 --- ---
Telephone --- 253 252
Computer sup. --- 93 ---
Maintenance --- --- 15,473
Misc. --- --- 1,325
Net Loss 20,711 31,467 49,152
The net loss reported for each year was offset against
petitioners' other income for those years. In addition,
petitioners claimed investment tax credits stemming from the
charter boat service for the years 1983 and 1984 in the amounts
of $2,430 and $711, respectively. Hans Hammann claimed and
received refunds of Federal income taxes paid for the years 1980
and 1981 as a result of carrying back his share of the unused
investment tax credits from 1983 and 1984 to those years.
For the year 1983, respondent determined that the charter
boat service constituted an activity not engaged in for profit
within the meaning of section 183 and allowed expenses only in
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