Gary W. and Darlene E. White - Page 4

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          sailboat named Moonshadow.3  Petitioners purchased Moonshadow new           
          in December 1997 for approximately $185,000, at which time they             
          traded in their former 36-foot Catalina sailboat.4                          
               Moonshadow is a single sloop mast sailboat with a diesel               
          engine.  It features, among other things, two double-berth                  
          staterooms, two cabins, two toilet compartments, and a galley               
          complete with a microwave, refrigerator, freezer, three-burner              
          propane gas stove with oven, and hot and cold running water.                
          Moonshadow also has on board a global positioning system with               
          chart plotter, an Autohelm navigation system, a Freedom 20                  
          inverter system, a TV/DVD, and a complete stereo system with                
          speakers in front and in back.  Petitioners took possession of              
          Moonshadow in March 1998, and have remained the sole owners of it           
          throughout the years in issue.                                              
               During the years in issue, petitioners docked Moonshadow at            
          the Anacortes Marina, which was operated by Anacortes Yacht                 
          Charters (AYC), a charter company.5  Petitioners initially                  

               3  Petitioners have owned various Catalina sailboats for the           
          past 40 years.  Mr. White is also an experienced sailor who built           
          his first boat at the age of 13 and crewed on boats racing in the           
          Columbia River.                                                             
               4  Petitioners apparently did not pay Washington State sales           
          tax when they purchased Moonshadow based on their declaration to            
          the Washington State Revenue Department that the sailboat was               
          purchased for charter purposes and not for personal use.                    
               5  AYC has a fleet of 110 boats, including Moonshadow,                 
          available for charters.  AYC also maintains skippers and crews              
                                                             (continued...)           





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