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On January 27, 1995, SMSM signed a charter agreement with
Priscilla Yacht Management under which the Feadship became a part
of Priscilla Yacht Management’s charter fleet operation. On
February 10, 1995, petitioner registered SMSM with the Florida
Department of Revenue as a sales and charter boat dealer.
On March 8, 1995, petitioner transferred title to the
Feadship to SMSM. Checking and credit card accounts were
established in the name of SMSM, and SMSM borrowed $874,000 to
refinance and to pay off the remaining balance on the $1 million
loan that petitioner had obtained to purchase the Feadship.
None of the members of the Magassy family were qualified
yachtsmen. From approximately March 16 through March 18, 1995,
however, Mrs. Magassy and petitioners’ three children were aboard
the Feadship during the Feadship’s first sea trial from
Ft. Lauderdale, Florida, to Port Lucaya, Bahamas. From March 24
through March 27, 1995, petitioners and their sons were aboard
the Feadship during a sea trial of the Feadship from
Ft. Lauderdale to Hurricane Hole, Bahamas. On at least three
additional occasions, different Magassy family members took
personal vacations on board the Feadship while it was in the
Bahamas.
On a number of occasions during 1995, 1996, and 1997,
petitioners held dinner cruises and cocktail parties on the
Feadship. Also, on occasion, without staying overnight, Magassy
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