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amortizable under section 263, capital expenditures, if made for
the personal benefit of the shareholder, can constitute
constructive dividends. See, e.g., Challenge Manufacturing Co. v.
Commissioner, 37 T.C. 650, 663 (1962); Gill v. Commissioner, supra.
The expenses incurred for the animal trophy collection were
composed mainly of costs associated with the acquisition and
display of the animal trophy mounts; i.e., acquisition and mounting
costs. Petitioners contend that the animal trophy collection was
to be used both as a marketing tool and as an amenity of Powhatan
Plantation. They allege the collection was to tour selected sites
around the country as well as to be placed in a “museum” located on
Powhatan Plantation. Petitioners assert that such displays would
attract potential buyers of the time-share intervals. However,
most of the animal trophy mounts were put on display at Bob’s and
the Y.O. Ranch.
We find petitioners’ argument unconvincing. Powhatan
Plantation had a colonial working plantation theme, emphasizing the
history of the Williamsburg-Jamestown, Virginia, area. The “world-
class” animal trophy mounts collection was designed to be composed
of exotic animals whose natural habitat did not include the
tidewater area of Virginia. We do not believe the display of
exotic animals such as elk, caribou, or Armenian red sheep furthers
the historical colonial theme that was in place as a marketing
strategy. In this respect we are mindful that notably absent from
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