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1. Net Worth Adjustments
a. Petitioners’ Snowmobiles
On December 31, 1986, petitioners each owned two
snowmobiles--each owned a 1987 Polaris Indy 600 and a 1987
Polaris Indy Sport. The 1987 Polaris Indy 600s were purchased
from Metro-North Sports on October 15, 1986, for the base price
of $4,688 each. Further, two items identified as “north country”
were purchased at the same time for $469 each. Although the
record does not disclose when the 1987 Polaris Indy Sports were
purchased, a receipt from Metro-North Sports shows that, on
October 29, 1986, petitioners purchased accessories and parts for
two “Indy 600s” and two “Sports”. Mr. Jacobsen disposed of his
Sport in 1988.
Mr. Del Bosque’s 1986 net worth statement includes only his
1987 Polaris Indy 600. The Sport, valued at $2,250, is shown as
an asset on his 1987 and 1988 net worth statements. In computing
Mr. Del Bosque’s taxable income under the net worth method, the
Sport should be included as an asset in the 1986 net worth
statement.
Mr. Jacobsen’s 1986, 1987, and 1988 net worth statements
include as an asset a snowmobile valued at $4,688 (the price of
the Indy 600). Although the snowmobile included in Mr.
Jacobsen’s net worth statement is not specifically identified,
the parties appear to agree that it is the Indy 600. Mr.
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