Randy L. and Julie J. Wysong - Page 10

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          Wysong Medical with additional equipment and services not                   
          specified in the lease agreements.  According to petitioners, the           
          lease agreements do not embody the entire agreement between the             
          two entities.  In addition to the physical space, petitioners               
          contend that Wysong Medical's rent payments included a premium              
          for: access to or use of Wysong Corp.'s equipment and employees;            
          and costs incurred on behalf of Wysong Medical by Wysong Corp.              
          for phone systems, computer systems, freight expenses, printing             
          expenses, fitness equipment, kitchen facilities, and inventory              
          used by Wysong Medical in its research and development                      
          activities.                                                                 
               Respondent argues that the lease agreements speak for                  
          themselves.  Alternatively, respondent argues that even if Wysong           
          Medical used additional space not reflected in the lease                    
          agreements petitioners failed to establish that the rental rate             
          was reasonable.  For example, petitioners failed to adduce                  
          evidence which establishes when the Eastman Building's addition             
          was completed and hence the square footage of the Eastman                   
          Building during the years in issue.                                         
               Respondent also attacks petitioners' second argument that              
          the parties to the lease agreements intended for the lease to               
          cover additional equipment and services.  Among other things,               
          respondent argues that Wysong Medical had no business purpose for           
          the sale and leaseback of its equipment and that the transaction            





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