- 3 -
This case was submitted with fully stipulated facts under
Rule 122. The stipulation of facts and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Freeport, Grand Bahama, Bahamas, when they filed their petitions.
Background
Petitioner formed Aqua Sun Investments, Inc. (Aqua Sun), as
a Florida corporation in 1984. Petitioner was the president and
sole shareholder of Aqua Sun from 1984 through 1995. In 1996,
petitioner's son acquired a .083 percent equity interest in Aqua
Sun, reducing petitioner's ownership percentage to 99.917
percent.
Aqua Sun was an S corporation during the years at issue.
During that time, Aqua Sun's primary business was the
development, construction, and sale of residential timeshare
units to individuals. Aqua Sun's timeshare development
activities have involved both the acquisition and the renovation
of existing buildings as well as the construction of new
facilities. All of Aqua Sun's timeshare developments are located
in either Ormond Beach, Daytona Beach, St. Petersburg, or
Kissimmee, Florida.
During the years in issue, Aqua Sun, in the ordinary course
of its business, sold residential timeshare units to individuals
on an installment basis whereby the sales price of a unit was to
be paid in installments over a specified period of time. Aqua
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011