Robert W. Tschetter - Page 27

                                       - 27 -                                         
          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            






Page:  Previous  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  Next

Last modified: May 25, 2011