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Moreover, since the depreciation respondent disallowed as a
deduction to Wolf Creek Farm was not an expenditure, we assume
that adjustments in the Tschetter notice of deficiency did not
include the depreciation.
We have computed the fair rental value of the farmhouse that
was included in respondent’s adjustment to Mr. Tschetter’ income
as follows:
11/30/95 11/30/96 11/30/97
Wolf Creek Farm notice of deficiency
Disallowed food & lodging deductions $6,176 $6,164 $5,287
Less depreciation on residence 569 587 575
Food & lodging expenditures 5,607 5,577 4,712
Tschetter notice of deficiency adjustment
for food & lodging provided by corporation$6,163 $6,218 $6,001
Food & lodging expenditures 5,607 5,577 4,712
Adjustment for rental value of residence 556 641 1,289
Mr. Tschetter has not shown that the portion of the rent
attributable to the farmhouse is less than the amounts for the
years at issue, as computed above. We therefore hold that those
amounts are properly included in Mr. Tschetter’s income for the
years at issue.
5. Summary of Adjustments to Mr. Tschetter’s Income
Mr. Tschetter’s income from farming is increased by $556 in
1995, $641 in 1996, and $1,289 in 1997 to reflect the
disallowance of deductions for the rental value of the farmhouse.
In addition, payments by Wolf Creek Farm for food and utilities
are included in Mr. Tschetter’s income as constructive dividends
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