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Sarasota, Florida, was Mr. Ciaravella's residence and
Icarus' principal place of business at the respective times they
filed their petitions.
Mr. Ciaravella is a calendar year taxpayer and the sole
shareholder of Icarus, a domestic corporation that filed
consolidated U.S. corporation income tax returns with its wholly
owned subsidiary, Dolphin Aviation, Inc. (Dolphin), on the basis
of a fiscal year ending August 31.
Icarus functions as the holding company for Dolphin, which
is a fixed-base operator of a general aviation facility at the
Sarasota/Bradenton International Airport. Dolphin leases 17
acres of land from the airport but owns all the improvements on
the land, including hangars, fuel farms, ramp areas, and office
space. Dolphin rents office space to aviation-related entities,
such as aircraft brokers and an aircraft sales company, provides
helicopter storage space for the Manatee County Sheriff's
Department, and rents hangar space for occupancy by private and
company-owned aircraft.
In its day-to-day operations, Dolphin provides transient
services, such as the sale of jet fuel, catering services, the
sale of airplane parts, and general maintenance and repair work
for aircraft flying into and out of the airport. Dolphin also
sells and leases aircraft, including selling used Learjets at
prices ranging from $200,000 to close to $2,000,000. The Learjet
is the DC-3 of the jet age, and its resale values have increased
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