- 9 - restoration of the Feadship totaled approximately $2 million. A memorandum petitioner received from the law firm noted that petitioner’s cumulative costs in purchasing and restoring the Feadship exceeded the Feadship’s fair market value and that yet additional significant costs would be necessary to complete the restoration of the Feadship. Petitioner was advised that a sale of the Feadship before completion of the restoration work and without establishing a yacht chartering operation for the Feadship would preclude treatment by petitioner of any loss on the sale of the Feadship as an ordinary loss under section 1231. In November of 1992, petitioners and Angus settled the above-referenced lawsuit pursuant to which petitioner agreed to pay Angus an additional $480,000 -- $300,000 in cash and a $180,000 promissory note with principal and interest due in 3 years. Petitioner paid Angus the $300,000, and Angus released the maritime lien on the Feadship. With petitioner’s consent, Captain Coby then transported the Feadship to a shipyard in Bayou La Batre, Alabama. At the shipyard in Bayou La Batre, much of the prior restoration work that had been done by Angus on the Feadship, at a cost to petitioner of approximately $1 million, was determined to be in need of being redone either because the work was defective or for other reasons. From late 1992 until June ofPage: 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