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the start and finish dates, the number of charter days, the
charter income, and the charter expenses. At the end of each
year, AYC would also mail petitioners a yacht owners’ annual
summary worksheet showing the monthly figures totaled for the
full year by income, charter expenses, and maintenance and other
expenses. These reports demonstrate that AYC arranged 13
charters for a total of 92 charter days in 1999 and 15 charters
for a total of 97 charter days in 2000.10
In addition to the services provided by AYC, petitioners
performed various services for their sailboat charter business.
For example, during the charter season petitioners would check on
the sailboat, wash the rugs, and perform maintenance.11
Specifically, in 1999 petitioners performed a major repair to
their sailboat when they installed a new windlass. At the end of
the charter season, petitioners would meet with the charter
representative to review the postseason report, which lists any
problems on the sailboat, the status of the systems, the
inventory on board, the hull condition, and any cosmetic
problems. During the off-season, petitioners would work on any
problems noted in the postseason report, conduct engine
10 In 1999, petitioners charted Moonshadow for a total of
12 charter days; in 2000, they charted Moonshadow for a total of
7 charter days.
11 AYC’s charter season is typically the last week of May
through the end of September.
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Last modified: May 25, 2011