- 19 - activity. Hans Hammann obviously derived a great deal of personal pleasure from sailing as evidenced by his desire to involve his son in the activity shortly after the child's birth. It is also obvious, based upon the types of expenses reported on the Schedules C, that sailing can be a financial burden. With the exceptions of a de minimis amount for advertising in 1984, and marginal fuel costs, the expenses incurred by petitioners in connection with the ownership and use of the Malaguena would have been incurred regardless of the operation of the charter boat service. Most likely Hans Hammann was aware of the fixed costs that would be involved in owning, maintaining, and sailing a boat such as the Malaguena. Given petitioners' financial status at the time the sailboat was acquired, he no doubt realized that he would have to offer the charter boat services in an attempt to subsidize such costs. Because of the demands of his employment with the union, Hans Hammann could only devote limited periods of time to the charter boat service. Considering such time limitations against Hans Hammann's practice not to offer the Malaguena for charter unless he was present on the boat, it would appear to be impossible for the charter boat service to be a profitable operation during the relevant years. We conclude that the Malaguena was acquired by petitioners for recreational purposes, albeit with the intent to offset some of the costs of ownership through the charter boatPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011