- 13 - not incurred in a trade or business. Respondent also removed the gross receipts received by Mr. Ciaravella and reported by him on the Innovative Schedules C and recharacterized and included them as constructive dividends. Although most deposits into Innovative's checking account were made by Dolphin, there were some deposits from other sources. In August 1992, R.C.I., of Naples, Florida, paid $1,700 for race car parts purchased from Mr. Ciaravella. In November 1993, the Model Search of Florida paid $2,065.50 to Mr. Ciaravella as compensation for the use of the race car as a prop in a movie production. In June and July 1993, Mark Pritch, another race car driver, paid $35,000 for the rental of Mr. Ciaravella's trailer and truck and other equipment. Dolphin also arranged to place its logo on power boats engaged in racing events sponsored by charities. The boating events averaged 10 races a year, at locations all across the country. These races also attracted upscale crowds. In exchange for being allowed to display its logo, Dolphin provided jet fuel to the boat owners when they were in the greater Sarasota area, including St. Petersburg and Tampa. Mr. Ciaravella deducted the cost of the boat fuel provided by Dolphin on his Innovative Schedules C for his 1992 and 1993 returns. Mr. Ciaravella's 1993 return was prepared by a Mr. Buchman, who is an employee of I D S Tax and Business Services. His 1992 return was not signed by a paid preparer. Vivian Wright,Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011