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Moreover, by securing the cap loan, petitioner was able to
raise the money necessary for the opening of the auto dealership.
Thus, in total, petitioner personally contributed approximately
$806,000 to the auto dealership. This investment was substantial
in nature.
At the inception of the auto dealership, petitioner secured
a $2.5 million floor plan arrangement to acquire inventory
(automobiles). Initially, petitioner was not required to
personally guarantee the floor plan arrangement. It was not
until July 31, 1988, that petitioner personally guaranteed the
floor plan loan. By that time, the floor plan amount had
increased significantly, permitting the auto dealership to have
an expanded inventory base.
The record, generally, reflects that petitioner's dominant
motivation was as an investor. His motivation in guaranteeing
the floor plan loan was to protect his investment in the business
of the auto dealership, as opposed to protecting his trade or
business as an employee.
Finally, in 1989, Sanwa Bank was concerned that the floor
plan amount was "out of trust" and requested that petitioner
decrease the outstanding loan. In the process, Sanwa Bank
received a $400,000 security interest in petitioner's home.
Sanwa Bank received $400,000 from the March 2, 1990, sale
proceeds from petitioner's home. Again, petitioner's dominant
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