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ers’ Schedule C gross receipts for 1995 by an additional $5,100.
Petitioners dispute that determination.
In support of their joint return position with respect to the
$5,100 of Loomis residence monthly payments, petitioners contend,
inter alia: “As the funds from Olin were conditional on the
rental of Petitioners’ home and the amount of those funds were
[sic] determined by the amount of rent the tenant paid, the funds
should be characterized as rental income.”
On the record before us, we reject petitioners’ contention.
The fact that the Loomis residence monthly payment was agreed to
in the Marion plant/Palmer consulting agreement because petition-
ers were renting their Loomis residence while Mr. Palmer was
consulting at the Marion plant does not require us to accept
petitioners’ contention that the Loomis residence monthly payments
in question constitute rent. Nor does the fact that the amount of
the Loomis residence monthly payment was determined as the approx-
imate difference between (1) the monthly rent that petitioners
were to receive on their Loomis residence throughout the period
during which Mr. Palmer was consulting at the Marion plant and
(2) the total amount of monthly mortgage, insurance, and mainte-
nance expenses that they were to pay on that residence throughout
that period require us to accept that contention.
In order to resolve the question presented with respect to
the $5,100 of Loomis residence monthly payments in question, we
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