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motivation was to protect his equity investment in the auto
dealership. Without the floor plan loan, petitioner's auto
dealership would have been critically impaired. See Tennessee
Sec., Inc. v. Commissioner, 674 F.2d at 574.
Overall, petitioner invested and assumed liabilities of
almost $700,000 and guaranteed several million dollars worth of
inventory. In contrast, his total salary over the same 4 years
was $893,833. In addition, petitioner remained liable for the
$1.1 million debt due Sanwa Bank after the foreclosure. These
figures contradict petitioner's argument that his total salary
comported with his exposure to liabilities.
2. Petitioner's Salary--Petitioner contends that he was
apprehensive about his position in Robertson Honda because his
salary was higher than comparable general managers, motivating
him to acquire an automobile dealership. Although petitioner
stated his beliefs as to general managers' salaries, no
comparable salaries of general managers were offered. Also,
petitioner had an "excellent" working relationship with the owner
of Robertson Honda, who assisted petitioner in obtaining an Acura
dealership franchise. These factors undermine petitioner's
contentions about the precarious nature of his salary and tenure
with Robertson Honda.
Petitioner asserts that he expected to make a salary ranging
from $750,000 to $3 million. His salary speculations were more
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