Gerald E. Johnson and Dorothy Johnson - Page 9

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               In G.E. Johnson, Inc.’s 1995 return, G.E. Johnson, Inc.,               
          reported that it did not pay any compensation to Mr. Johnson or             
          Ms. Johnson as officers of that company.  In that return, G.E.              
          Johnson, Inc., reported that it paid $47,040 of salaries and                
          wages, although it did not identify in that return the person or            
          persons to whom it paid those wages.  In G.E. Johnson, Inc.’s               
          1995 return, G.E. Johnson, Inc., reported that it paid $175,497             
          in rent, although it did not specify in that return the amount of           
          such rent that it paid to petitioners during its taxable year               
          ended October 31, 1995.                                                     
               In G.E. Johnson, Inc.’s 1996 return, G.E. Johnson, Inc.,               
          reported that it did not pay any compensation to Mr. Johnson or             
          Ms. Johnson as officers of that company.  In that return, G.E.              
          Johnson, Inc., reported that it paid $49,816 of salaries and                
          wages, although it did not identify in that return the person or            
          persons to whom it paid those wages.  In G.E. Johnson, Inc.’s               
          1996 return, G.E. Johnson, Inc., reported that it paid $181,763             
          in rent, although it did not specify in that return the amount of           
          such rent that it paid to petitioners during its taxable year               
          ended October 31, 1996.                                                     
               On January 22, 1998, respondent issued a notice to petition-           
          ers with respect to their taxable years 1993, 1994, and 1995.  In           
          that notice, respondent determined that the 1993 claimed rent,              
          the 1994 claimed rent, and the 1995 claimed rent, reduced by the            






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