Gerald E. Johnson and Dorothy Johnson - Page 7

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          farmland and personal property (1995 claimed rent), $32,018 in              
          expenses, and $72,860 in total rental real estate income.                   
          Immediately prior to the trial in this case, petitioners conceded           
          that $44,878 of the $104,878 of the 1995 claimed rent was not               
          received for the lease of petitioners’ farmland and personal                
          property pursuant to the oral rental arrangement and is subject             
          to self-employment tax.  (For convenience, we shall refer to the            
          $60,000 balance ($104,878 minus $44,878) of such claimed rent as            
          the modified 1995 claimed rent.)                                            
               The 1993 claimed rent, the 1994 claimed rent, and the                  
          modified 1995 claimed rent that petitioners received during the             
          respective years at issue from G.E. Johnson, Inc., pursuant to              
          the oral rental arrangement represented fair market rents and are           
          consistent with the rents paid during those years by G.E. John-             
          son, Inc., to other third-party landlords.                                  
               G.E. Johnson, Inc., filed Form 1120, U.S. Corporation Income           
          Tax Return, for each of its taxable years ended October 31, 1993            
          (G.E. Johnson, Inc.’s 1993 return), October 31, 1994 (G.E.                  
          Johnson, Inc.’s 1994 return), October 31, 1995 (G.E. Johnson,               
          Inc.’s 1995 return), and October 31, 1996 (G.E. Johnson, Inc.’s             
          1996 return).  In G.E. Johnson, Inc.’s 1993 return, G.E. Johnson,           
          Inc., reported that it paid $20,000 of compensation to Mr.                  









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