- 6 - 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’sPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011