Morgan L.Lucid and Mary J. Lucid - Page 25

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          their losses by changing their approach.  Hence, Pryor v.                   
          Commissioner, supra, is distinguishable.                                    
               Petitioners also rely on Dickson v. Commissioner, T.C. Memo.           
          1983-723, in which we found that despite losses, due to economic            
          conditions, the taxpayer was engaged in the business of                     
          chartering his boat with a profit motive.  We also found that the           
          taxpayer actually and honestly expected his boat to appreciate.             
          However, this case is inapposite; petitioners did not purchase              
          and hold Brendan or Trinity in order to derive gains from long-             
          term appreciation.  There is also nothing on the record from                
          which we can conclude that the value of the yachts would have               
          increased.                                                                  
               Petitioners also cite Jackson v. Commissioner, 59 T.C. 312             
          (1972).  In Jackson, we determined that the taxpayer was in the             
          trade or business of renting his yacht.  Despite bad weather and            
          damage to the yacht, which forced the taxpayer to cancel most               
          charters, he took other steps to carry on his activity for                  
          profit.  For example, the taxpayer changed the venue of his                 
          activity to the Virgin Islands, where his sailing vessel was in             
          demand.  The taxpayer also began a national advertising campaign.           
          In that regard, he engaged a celebrity to advertise his business            
          throughout the nation.  We find petitioners' reliance on Jackson            
          to be distinguishable.  Here, petitioners did not take alternate            
          steps to carry on their yacht-related activity in a profit-                 
          oriented manner.  Petitioners' cessation of their activity                  



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