Winston Knauss - Page 5

                                        - 5 -                                         
          price for the yacht.  Shortly after taking delivery, petitioner             
          paid $2,683 to install deck lights.                                         
               In 1992, petitioner advised his return preparer that the               
          purchase price of the yacht was $833,218.                                   
               On January 27, 1994, petitioner sold the Wrecking Krew to              
          Dream USA, Inc., for $950,000.4  At the time of sale, petitioner            
          incurred the following costs: $13,068 for lead ballast; $1,000              
          for lead ballast installation; $5,563 in architect’s fees; and a            
          sales commission of $51,000.  The sum of the foregoing items,               
          plus the contract price paid to Marine Builders, Inc., and the              
          cost of the deck lights, equaled $870,021.                                  
               Petitioner reported on his 1994 return that his basis in the           
          Wrecking Krew (plus selling expenses) was $1,025,869.  Adjusted             
          basis reported on the return, as a result of a claim of $100,740            
          in depreciation, was $925,129, resulting in a reported gain of              
          $24,871 on the sale of the vessel.  Accepting petitioner’s                  
          claimed depreciation, respondent nonetheless determined that                
          petitioner’s adjusted basis in the vessel at the time of sale had           
          been overstated by $156,848, resulting in a determination of                
          unreported gain in that amount.  In the answer, respondent                  



               4 By the time of the sale, petitioner had renamed the vessel           
          Sir Winston, the same name used for the two other vessels at                
          issue in this case.  For simplicity, we shall refer to this                 
          vessel as the Wrecking Krew.                                                





Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011