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35.5 to be used for a general business office, staff and client
meetings, and corporate entertainment for a purchase price of
approximately $67,000". On or about August 29, 1997, petitioner
purchased the sailboat at issue, a 42-foot Centurion yacht
(Centurion), for $155,000.3 Petitioner’s board resolved as to
the Centurion that “It is in the best interest of the Corporation
to purchase a 1985 Centurion 42 by Wauquiez to be used for a
general business office, staff and client meetings, and corporate
entertainment for a purchase price of approximately $155,000".
At the time of the last resolution, petitioner was headquartered
in two or three suites of offices in Burbank, California. Those
suites included at least one production studio and at least eight
editing rooms.
Before petitioner purchased the Centurion, Roach had done
little sailboat racing. Roach considered the purchase of the
Centurion to be an opportunity for him to compete in performance
racing. The Centurion is a very high class, powerful sailboat
that was built in 1985 and is considered to be a prestigious and
luxurious yacht that is one of the fastest yachts of great
international class. From an operation point of view, the
Centurion was designed for pure sailing joy and has a helm that
3 Petitioner disposed of the Catalina before purchasing the
Centurion, and it sold the Beneteau 4 days after it purchased the
Centurion. In addition to these three boats, Roach, either
personally or through petitioner, purchased three other
sailboats.
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