Gary W. and Darlene E. White - Page 8

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          maintenance, refinish the interior, wax the sailboat, and switch            
          the pumps.  During the preseason, petitioners would conduct a               
          maintenance check, which AYC would verify based on a preseason              
          readiness checklist.  Petitioners also rented a storage locker in           
          the marina building where they stored proprietary parts that AYC            
          or petitioners could use for repairs on Moonshadow.                         
               To document their work, petitioners maintained                         
          contemporaneous handwritten logs identifying the dates that they            
          worked on Moonshadow and the type of work completed.  The work              
          logs indicate a timeframe for each day Mr. White or petitioners             
          together worked on Moonshadow.  The work logs, however, do not              
          detail the amount of time actually spent on a specific task, do             
          not indicate which petitioner performed a particular task, and do           
          not account for lunch breaks that petitioners testified they took           
          during the day.                                                             
               Petitioners timely filed a Form 1040, U.S. Individual Income           
          Tax Return, for each of the years in issue.  Petitioners attached           
          to each return, inter alia, a Schedule C, Profit or Loss From               
          Business (Sole Proprietorship).  On each Schedule C, petitioners            
          identified their business name as GW Rentals and their principal            
          business or profession as boat charters and tours.  On the                  
          Schedules C, petitioners marked “Yes” on Line G:  “Did you                  
          ‘materially participate’ in the operation of this business”.                
          Petitioners reported losses from GW Rentals on the Schedules C as           






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Last modified: May 25, 2011