Jackson v. Commissioner
United States Tax Court
Petitioner purchased a 65-foot yacht in 1958. Over the next few years he made extensive repairs and improvement. In 1961 he investigated the chartering business and found the Virgin Islands to be the most desirable area for chartering. Petitioner had the boat brought to the Virgin Islands in 1964. During 1965, the yacht produced $ 30,000 in gross revenues from charters and made a small profit.
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Petitioner purchased a 65-foot yacht in 1958. Over the next few years he made extensive repairs and improvement. In 1961 he investigated the chartering business and found the Virgin Islands to be the most desirable area for chartering. Petitioner had the boat brought to the Virgin Islands in 1964. During 1965, the yacht produced $ 30,000 in gross revenues from charters and made a small profit. Because of delays in returning from an extended charter, caused by bad weather and damage to the yacht, petitioner was forced to cancel most charters for the 1966 season. Held: Petitioner was in the…
1Opinion of the Court
Sterrett, Judge'-
Respondent determined a deficiency in petitioner’s Federal income tax and an addition to tax in the following amounts:
Addition to tax Year Deficiency under sec. 6658 (a)1
1966_$6,608. 58 $330.43
At issue in this case is the deductibility of expenses and depreciation, pursuant to sections 162(a) and 167(a), respectively, incurred by the petitioner in the operation of the yacht Thane during 1966. Further we must also determine whether any portion of the asserted deficiency is due to negligence or intentional disregard of the rules and regulations.
FINDINGS OF FACT
Some of the facts…
2Cases cited8 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Margit Sigray Bessenyey v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1967
- Marcello v. CommissionerUnited States Tax Court · 1964
- Corliss Lamont and Margaret I. Lamont v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1964
- Wilson v. EisnerCourt of Appeals for the Second Circuit · 1922
3 more not listed; retrieve them via the Exa API.
3Cited by62 opinions
- Hunter Faulconer, Sr. And Mary T. Faulconer v. Commissioner of Internal RevenueCourt of Appeals for the Fourth Circuit · 1984
- Gestrich v. CommissionerUnited States Tax Court · 1980
- Giles v. Comm'rUnited States Tax Court · 2006
- Roberts v. CommissionerCourt of Appeals for the Seventh Circuit · 2016
- Hoyle v. CommissionerUnited States Tax Court · 1994
57 more not listed; retrieve them via the Exa API.