Csaba L. Magassy and Frances H. Magassy - Page 22

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          748 F.2d 890, 893 (4th Cir. 1984), revg. and remanding T.C. Memo.           
          1983-165.                                                                   
               The losses petitioner claimed relating to the Feadship                 
          generated significant claimed tax savings, which, if allowed,               
          would offset income from petitioner’s unrelated medical practice.           

          History of Income or Losses                                                 
               Substantial losses over a number of years suggest a lack of            
          profit objective.  Sec. 1.183-2(b)(6), Income Tax Regs.  If,                
          however, losses result because of unforeseen circumstances beyond           
          the control of a taxpayer, the losses may bear less on the                  
          question of profit objective.  Id.                                          
               Chartering the Feadship resulted in losses to petitioner for           
          all 3 years at issue.  The excessive costs relating to the repair           
          and restoration work on the Feadship may have been a surprise to            
          petitioner, but good faith, diligent, and timely investigation              
          into the condition of the Feadship and into the nature of the               
          luxury yacht charter business would have eliminated most of this            
          surprise and would have provided to petitioner information upon             
          which he would have been able to make a reasoned and calculated             
          decision about whether to proceed further.                                  
               By 1995, petitioner’s costs associated with the Feadship               
          were so high that he should have known that charter of the                  
          Feadship would not generate income sufficient to cover those                
          costs.  Further, in 1995, 1996, and 1997, while the Feadship was            
          available for charter, the Feadship also was for sale at an                 






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