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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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