Randy L. and Julie J. Wysong - Page 14

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          property.  Among other things, petitioners argue that the                   
          reasonableness of Wysong Medical's rent is evidenced by the                 
          proportionally similar income and losses reported by both the               
          lessor and the lessee.  For example, in 1992, Wysong Medical's              
          total deductions represented approximately 101 percent of its               
          gross income, whereas Wysong Corp.'s total deductions represented           
          approximately 99 percent of its gross income.  Petitioners                  
          contend that this balancing of income and losses was done by                
          design, and that this proportionality establishes that there was            
          no improper shifting of income.                                             
               Respondent argues that Wysong Medical's payments were not              
          reasonable in light of all the facts and circumstances.  First,             
          and using the square footage identified in the lease agreements,            
          respondent argues that parties in an arm's-length transaction               
          would not have agreed to rent office space at $184 per square               
          foot when the prevailing rate in the area was $13 per square                
          foot.  Second, respondent argues that the amount of rent paid by            
          Wysong Medical was not reasonable in relation to the business               
          activities of the two corporations.  In 1992 and 1993, Wysong               
          Medical's gross receipts were $147,341 and $100,537,                        
          respectively; whereas Wysong Corp.'s gross receipts were                    
          $2,436,888 and $2,666,759 in 1992 and 1993, respectively.  Yet,             
          the amount of rent paid by Wysong Medical represented 69 percent            
          and 35 percent of the total rent paid by Wysong Corp. in 1992 and           





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