Thomas C. Oberle and Margaret Colbert Oberle - Page 3

                                        - 3 -                                         

          percent of charter revenues.  The agreement further provides that           
          petitioners (1) are required to maintain the yacht in good                  
          condition and (2) have the right to operate the yacht for                   
          personal use, provided such use does not conflict with the                  
          yacht's charters.                                                           
               At the end of October 1993, petitioners removed the yacht              
          from the water and placed it in storage for the winter at Benton            
          Harbor, Michigan.  From September 11 through December 20, 1993,             
          petitioners worked on the yacht for a total of approximately 53             
          hours.  Most of this time was spent traveling to the storage                
          facility where they cleaned and winterized the yacht.  The yacht            
          was not chartered in 1993.                                                  
               On April 23, 1994, petitioners sailed the yacht to Michigan            
          City.  During 1994, the yacht was chartered 45 days, and                    
          petitioners received gross receipts of $5,152.  Petitioners                 
          occasionally used the yacht for personal enjoyment.  On October             
          22, 1994, petitioners removed the yacht from the water and placed           
          it in storage for the winter.  During 1994, petitioners worked on           
          the yacht for a total of 194 hours, but only 89 hours of such               
          work was performed while the yacht was docked at Michigan City.             
          Petitioners spent most of this time performing routine                      
          inspections and maintenance of the yacht.  From 1993 through 1996           
          petitioners did not make a profit from their chartering activity.           
          On their returns, petitioners claimed net losses of $21,858 for             





Page:  Previous  1  2  3  4  5  6  Next

Last modified: May 25, 2011