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All section references are to the Internal Revenue Code as in
effect for the years in issue. All Rule references are to the Tax
Court Rules of Practice and Procedure. All dollar amounts are
rounded.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found. The
stipulations of facts, stipulations of settled issues, and attached
exhibits are incorporated herein by this reference.
Background
Petitioners, husband and wife, resided in Norfolk, Virginia,
at the time they filed their petition.
Kay F. Gow (Dr. Gow) earned a doctor of education (Ed.D.)
degree from Virginia Tech., specializing in business education. As
part of her curriculum she took courses in accounting. Before
1983, she taught and supervised a business education program at a
public high school in Virginia. At the time of trial, Robert T.
Gow (Mr. Gow) was a retired civil service employee.
Williamsburg Vacations, Inc. (WVI)
WVI was incorporated under the laws of Virginia on July 21,
1983. In November of 1986, WVI became a partner in a joint venture
known as Powhatan Associates. (The other two members of the joint
venture were Offsite International (Offsite) and Bush Construction
Co. (Bush). None of the joint venturers were related; each held a
one-third interest in Powhatan Associates.) During the years in
issue, WVI’s sole income-producing property was its indirect
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Last modified: May 25, 2011