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Sundancer with twin 270 horsepower Mercruiser gasoline engines.
The auction was a foreclosure sale instituted by General Motors
Acceptance Corp. (GMAC), a mortgage creditor. Petitioner was
familiar with the boat, as it had been docked next to another
boat owned by him. In the few months prior to the auction sale,
petitioner looked after the boat for GMAC. After the purchase,
petitioner added certain components to the boat. The boat was
recreational and was not used in petitioner's trade or business.
During 1994, petitioner had the boat towed to Daytona, Florida,
for his personal use in that area. While he was using the boat
at Key West, Florida, petitioner met two individuals, identified
by petitioner as marine surveyors, who were affiliated with an
organization known as Institute of Marine Services (IMS) of
Lauderdale-By-The-Sea, Florida. These individuals, after
explaining the work of IMS, requested that petitioner consider
donating the boat to IMS, and, since IMS was a tax-exempt
organization under section 170(c), petitioner would be entitled
to an itemized charitable contribution deduction for Federal
income tax purposes for the value of the boat. Petitioner was
interested but felt that the income taxes he would save by way of
the charitable contribution would not totally compensate him for
2(...continued)
boat. In the written stipulation, the parties agreed the
purchase price was $53,500; however, at trial, petitioner
testified he paid $53,000 for the boat.
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