- 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