- 3 -
and 6,296 square feet of office-work area. The 25,196 square
feet includes an addition which was made after the years in issue
and which increased the warehouse section of the building by
approximately twofold. On petitioners' 1992 and 1993 tax
returns, the Eastman Building's total asset cost was identified
at $403,400.
Randy L. Wysong (Dr. Wysong) is a doctor of veterinary
medicine. In the early 1980's, he purchased all the stock of
Vet-Med Health Products, a company in the business of nutritional
products designed for veterinary clinical use. Dr. Wysong
subsequently changed the name of the company to Wysong Medical.
Prior to 1992, Wysong Medical conducted research and development
activities and manufacturing and marketing activities. Also
prior to 1992, Wysong Medical leased the Eastman Building from
petitioners for an amount and under terms not disclosed by the
record, and it owned all the personal property in the Eastman
Building.
Due, in part, to liability concerns, Dr. Wysong decided to
separate research and development activities from manufacturing
and marketing activities. To accomplish this end, Dr. Wysong, in
or around 1991, founded Wysong Corp. to market products developed
by Wysong Medical.1 Dr. Wysong is Wysong Corp.'s sole
1 Wysong Corp. also manufactures a limited amount of these
products.
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