- 7 - contacts in the industry, petitioners were able to recruit a capable, professional crew. The bank records of Diane Racing were originally maintained in Washington, D.C., so Benjamin could oversee the account while he was in Washington, D.C. Petitioners paid some boat expenses through their personal checking accounts because some expenses needed to be paid immediately and there was a lag time for checks to clear from the bank account in Washington, D.C. Once Benjamin left Washington, D.C., the bank account was moved to New York. During the years in issue, the Diane participated in four to nine events each season, and each event could involve multiple races. The Diane received publicity because of its photos in sailing calendars, in a Patagonia catalog, and in a commercial for an Italian deodorant company. The crew on the Diane was professionally operated. To participate in a race, the Diane required a crew of 15 members. Petitioners’ children had participated as members of the crew; however, they would sail rarely because the children lived in different cities. Mrs. Schwartz has not stepped aboard the Diane since 1991 because of an arthritic condition. The Activity Petitioners expected the Diane to make a profit through the following ways: (1) Obtaining sponsorships that includedPage: 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