- 7 - There were a total of five beds in the habitat. The vessel was rechristened “Jules Undersea Lodge” (JUL). By the end of 1986, JUL was submerged in a lagoon located in Key Largo, Florida. JUL had its first overnight guest by 1986. By 1989, the vessel and its related equipment were transferred to Sealodge. The cost to build a vessel in accordance with the standards of the American Board of Shipping (ABS) and to have the vessel certified by the ABS would be from 25 to 50 percent more than the cost to build the same vessel without ABS certification. JUL has never been certified by ABS. JUL has been subject to a regular maintenance program, but there have been no major renovations to it since 1986. During the years prior to and following the contribution in dispute, approximately 90 percent of JUL’s usage was as an undersea hotel. The remaining use has been as a research facility. The operation of JUL as an undersea hotel had net operating losses for the 4 years prior to the charitable contribution ranging from $5,434 to $21,067. OPINION In this valuation dispute, the parties adopt very similar methodologies but use widely different estimates of the elements of the methodologies they apply. Petitioners’ position presents an internal inconsistency between the estimate of replacementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011