- 15 - 1993, respectively. According to respondent, it was not reasonable for Wysong Medical to pay such portions of the rent. Third, respondent argues that Wysong Medical's payments to Wysong Corp. were made as a means of shifting income with the end effect being a decrease in the amount of flow-through income from Wysong Medical, an S corporation, to its sole shareholder Dr. Wysong. We are not satisfied that the amount of rent paid by Wysong Medical was reasonable, in other words, that a lessee in an arm's-length transaction with an unrelated party would have paid the amount of rent that Wysong Medical was required to pay under the lease agreements. We reject petitioners' argument that the corporations' proportionally similar income and losses for the years in issue demonstrates that there was no improper shifting of income and that the amount of rent paid by Wysong Medical was reasonable. We believe that the relevant inquiry focuses not only on the effect that these deductions had on the two corporations but also on the effect that the deductions had on the S corporation's sole shareholder, Dr. Wysong. Furthermore, we find that Wysong Medical's rent payments were not reasonable in relation to the corporations' business activities. In 1992 and 1993, Wysong Corp. had gross income in the amounts of $2,436,888 and $2,666,759, respectively, and made rent payments to petitioners in the amounts of $132,842 and $131,520. The rent payments were approximately 5.5 percent andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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