- 8 - Although after May 28, 1996, petitioner used the floating structures approximately 10 times a year for personal purposes, including the storage of his boat and jet skis, he paid $80,717 out of his own pocket to construct the floating structures.9 Consequently, his interest (approximately 30 percent) in the structures allowed him a reasonable amount of personal use without conferring an economic gain or benefit upon him. The record does not indicate petitioner used the floating structures in an unreasonable manner. Therefore, this Court finds petitioner did not receive an economic gain or benefit from his personal use of the floating structures. Accordingly, petitioner did not receive a constructive dividend for the amounts VVI paid to construct the floating structures. The Court, in reaching its holding, has considered all arguments made and concludes that any arguments not mentioned above are moot, irrelevant, or without merit. To reflect the foregoing, Decision will be entered for petitioner. 9 Total cost of constructing the floating structures was $266,044, of which VVI and petitioner paid approximately 70 percent ($185,327) and 30 percent, respectively.Page: Previous 1 2 3 4 5 6 7 8Last modified: November 10, 2007