Robert & Diane Schwartz - Page 6




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          J-27 sailboat) which were used solely for recreation and                    
          maintained near petitioners’ residence.  The Diane, because of              
          its vast size, was maintained in a professional yard in                     
          Jamestown, Rhode Island, a 5-hour drive from petitioners’                   
          residence.  The Diane was also stored out of the water on dry               
          dock.                                                                       
               After joining the Association, knowing of the sponsors, and            
          purchasing the Diane, in August 1991, petitioners incorporated              
          Diane Racing.  Mrs. Schwartz was the sole shareholder of Diane              
          Racing.  Diane Racing was incorporated as an S corporation.                 
               Petitioners had experience in business from their rental               
          real estate business (Schwartz Realty) in Washington, D.C.  Mrs.            
          Schwartz did the paperwork for Diane Racing, such as paying the             
          bills, maintaining an annual ledger and other financial records             
          (e.g., keeping the canceled checks of expenses paid), maintaining           
          correspondence, sending out promotional mailings, making boat               
          arrangements (e.g., transporting the boat), and creating and                
          maintaining a Web site for Diane Racing.  Petitioners spent an              
          average of 15 to 20 hours per week on Diane Racing.                         
               Petitioners’ son Benjamin was named president of Diane                 
          Racing.  Having Benjamin as president allowed Diane Racing to               
          qualify for lower insurance rates because Benjamin had a                    
          captain’s license and was capable of repairing the Diane’s                  
          engine.  Additionally, through petitioners’ and Benjamin’s                  






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Last modified: May 25, 2011