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