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Wysong Medical's share of the utilities was factored into its
rent payment. And finally, in 1992 and 1993, Wysong Medical
deducted $70,000 and $48,309, respectively, for "commissions" and
"contract work" expenses. Ms. Hubbard testified that the $70,000
deduction for "commissions" was for contract labor performed by
employees of Wysong Corp. This undercuts petitioners' argument
that Wysong Medical's rent payments included a premium for the
use of Wysong Corp.'s employees. Petitioners further argue that
the rent payment included a premium for access to, and not the
use of, Wysong Corp.'s employees. This argument lacks merit. It
is well-settled law that a deduction claimed for rent is only
allowable where the payment is actually made for rent and not for
something else in the guise of rent. Mackinac Island Carriage
Tours, Inc. v. Commissioner, 419 F.2d 1103, 1105 (6th Cir. 1970);
Place v. Commissioner, 17 T.C. at 203; American Metal Prods.
Corp. v. Commissioner, 34 T.C. 89, 105 (1960), affd. 287 F.2d 860
(8th Cir. 1961) ("To the extent * * * [payments were not made for
rent], such payments would not be ordinary and necessary and
therefore would not be deductible as rental expenses").
Rejecting petitioners' arguments as to square footage,
property, and services not identified in the lease agreements, we
now turn to the parties' remaining arguments for and against the
reasonableness of the rent. Neither party presented expert
testimony to establish the fair rental value of the leased
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