- 35 - A similar result obtains with respect to the Sir Winston II. Respondent’s analysis of the two checking accounts and one brokerage account held by petitioner during the 1-year period following his acquisition of the Sir Winston II concluded that petitioner could not have expended more than $72,315 from these sources for capital improvements to that vessel. Upon review of respondent’s analysis, we conclude that five additional checks that were not treated by respondent as possible capital improvements expenditures should have been so treated. Those checks include two checks to “Costco” totaling $1,901, two checks to “Henry Lee Co.” totaling $2,226, and a check to “Weaver & Weaver, P.A.” for $2,905. We conclude that the payees on these checks do not provide a sufficient basis to exclude them as possible expenditures for capital improvements. The total of the foregoing additional checks is $7,032, which when added to respondent’s calculation brings the total of possible capital expenditures from petitioner’s checking and brokerage accounts to 22(...continued) builder had completed it. Nonetheless, a marine survey conducted 3 days before petitioner took possession found that the vessel was 95 percent complete, and a U.S. Coast Guard certificate of inspection, qualified by minor deficiencies, was issued at the same time. Moreover, petitioner settled his lawsuit against the builder for $65,000, a figure that is inconsistent with the claim that expenditures exceeding $500,000 were required to complete the Sir Winston after petitioner took possession. Thus, we do not believe that the somewhat unfinished state of the Sir Winston when petitioner took possession can account for the remainder of the $527,074 in claimed, but unsubstantiated, capital improvements.Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 Next
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