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over time. Dolphin purchases used Learjets, many of which are 20
and 30 years old, replaces the engines, rehabilitates, repairs,
and paints them, and then leases them to corporations and
individuals. Between leases, Dolphin tries to sell the jets.
Sarasota Jet Center, Inc. (Sarasota), and Nomad Distributors
Intl., Inc. (Nomad), are corporations that are also directly or
indirectly owned or controlled by Mr. Ciaravella. They are
members of a controlled group of corporations, within the meaning
of section 1563(a), which includes Icarus and Dolphin, but are
not included on the Icarus consolidated return because they are
not members of the Icarus affiliated group within the meaning of
section 1504(a). Sarasota and Nomad also sell aircraft and at
times buy aircraft from Dolphin and then sell them to third
parties.
The following are the yearend cost balances of aircraft
owned by Dolphin2 and held for sale or lease:
FYE 1991 FYE 1992 FYE 1993
$2,958,000 $2,668,000 $3,893,000
2 The Court requested the parties to provide posttrial
information as to the yearend inventory balances of aircraft
owned by Dolphin. Petitioner submitted inventory balances for
aircraft owned by Dolphin and other corporations that are
directly or indirectly owned by Mr. Ciaravella. Our findings
concerning the yearend inventory balances are based on the costs
of the aircraft that petitioner has proven belonged to Dolphin
during the years in issue.
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Last modified: May 25, 2011