Lee D. Froehlich - Page 29

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          anecdotal than factual.  We note that petitioner did not offer              
          Robertson's testimony or that of other auto dealers.                        
               Petitioner did offer the testimony of Ms. Rugh, the auto               
          dealership's accountant.  Ms. Rugh thought petitioner's salary              
          was low when compared to other auto dealers with which she was              
          familiar.  Petitioner, however, did not provide a plausible                 
          explanation as to why his salaries were substantially less than             
          he testified others were, especially considering the exclusivity            
          of his auto dealership's geographic market (the San Fernando                
          Valley) for the first 2 years.  In that regard, petitioner's auto           
          dealership was the number one Acura dealership in the nation for            
          its first 2 years.                                                          
               Finally, subsequent to the foreclosure of the auto                     
          dealership, petitioner's salary level working for other                     
          dealerships was comparable to his earnings when he worked for his           
          own dealership.  Accordingly, petitioner knew that with his                 
          experience and background in the automobile sales field, he would           
          be able to obtain employment and commensurate levels of                     
          compensation elsewhere.                                                     
               3.  Other Factors--During the first 2 years, petitioner's              
          business was the number one Acura dealership in the country.  His           
          auto dealership demonstrated, generally, increases in gross                 
          receipts of $7,414,704, gross profits of $577,060, and total                
          income of $594,819 in 1988 compared to the year before.  Despite            





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