Leslie A. and Betsy M. Roy - Page 2

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          respectively.  The issues for decision are:  (1) Whether                    
          petitioners are entitled to rental expense deductions for a                 
          personal residence; and (2) whether petitioners are entitled to             
          exclude payments by their employer for use of their personal                
          residence.                                                                  
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by reference.  Petitioners resided in Moxee,            
          Washington, at the time they filed their petition.                          
                                     Background                                       
               When Leslie Roy (petitioner) was in high school, he began              
          working on his family's farm, Roy Farms, Inc. (Roy Farms or the             
          farm).  Roy Farms is a large farm, owning more than 5,000 acres             
          of land and harvesting crops such as apples, hops, sweet                    
          cherries, and alfalfa.  The farm also maintains approximately               
          1,000 head of cattle.                                                       
               Roy Farms is an S corporation, of which petitioner holds a             
          minority interest.  In 1992, he held 8.15 percent of Roy Farms'             
          shares and in 1993, he held 10.39 percent.  The remainder is held           
          by petitioner's three brothers and his parents.  Lester Roy,                
          petitioner's father, is the president of Roy Farms.                         
               Petitioner has worked steadily on the farm since high                  
          school, taking only a temporary break to earn his college degree            







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