IRS agreed owner of yacht charter business materially participated

The IRS asserted that the taxpayer did not materially participate in his yacht charter business and therefore the business was passive and his losses were not deductible.

Through a chronology of Petitioner’s business records, charter agreements, phone records, emails, and co-worker’s testimonials, the taxpayer established that he not only materially participated in the business operations of his yacht charter business, but also micro-managed that business from Atlanta, Georgia.