- 8 - Winston was $1,200,000. Adjusted basis reported on the return, as a result of a claim of $33,360 in depreciation, was $1,166,640, resulting in a reported gain of $83,360 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 was $639,566, or $527,074 less than claimed by petitioner, resulting in a determination of unreported gain in that amount. Sir Winston II On December 5, 1994, petitioner entered into a fixed-price contract with Marine Builders, Inc., to build a yacht to his specifications for $1,099,173. Petitioner made cash payments totaling $39,000 toward the construction of the yacht. Petitioner also made direct payments to vendors totaling $33,330 for improvements to the yacht during its construction. The yacht was issued a certificate of inspection by the U.S. Coast Guard and assigned identification No. D1037815. The yacht was delivered complete and ready to carry passengers for hire on January 11, 1996. Petitioner also named this vessel the Sir Winston (Sir Winston II). During the 1-year period after petitioner took delivery of the Sir Winston II (January 11, 1996 to January 11, 1997), petitioner had two checking accounts and a brokerage account on which he could draw checks. During this period, the checks drawnPage: 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