- 7 -
farmland and personal property (1995 claimed rent), $32,018 in
expenses, and $72,860 in total rental real estate income.
Immediately prior to the trial in this case, petitioners conceded
that $44,878 of the $104,878 of the 1995 claimed rent was not
received for the lease of petitioners’ farmland and personal
property pursuant to the oral rental arrangement and is subject
to self-employment tax. (For convenience, we shall refer to the
$60,000 balance ($104,878 minus $44,878) of such claimed rent as
the modified 1995 claimed rent.)
The 1993 claimed rent, the 1994 claimed rent, and the
modified 1995 claimed rent that petitioners received during the
respective years at issue from G.E. Johnson, Inc., pursuant to
the oral rental arrangement represented fair market rents and are
consistent with the rents paid during those years by G.E. John-
son, Inc., to other third-party landlords.
G.E. Johnson, Inc., filed Form 1120, U.S. Corporation Income
Tax Return, for each of its taxable years ended October 31, 1993
(G.E. Johnson, Inc.’s 1993 return), October 31, 1994 (G.E.
Johnson, Inc.’s 1994 return), October 31, 1995 (G.E. Johnson,
Inc.’s 1995 return), and October 31, 1996 (G.E. Johnson, Inc.’s
1996 return). In G.E. Johnson, Inc.’s 1993 return, G.E. Johnson,
Inc., reported that it paid $20,000 of compensation to Mr.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011