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were to (1) arrange financing, (2) sell insurance and warranties,
(3) assist customers with their automobile registration, and (4)
make leasing arrangements. Petitioner's duties as a business
manager generally took place after a deal was agreed to for the
sale of an automobile. However, at times, petitioner arranged
the automobile sale.
Petitioner received $163,289 commission income from the
Crabtree Dealerships in 1987. Petitioner's business manager
commissions were directly tied to the amount of financing and
other arrangements he successfully concluded and were not based
on a pool of all business managers at the Crabtree Dealerships.
In those instances when petitioner arranged for sales of
automobiles, not merely financing, etc., petitioner’s commissions
were based on the entire sales price. Petitioner sold about 50
automobiles in 1987.
When petitioner referred customers to other Crabtree
Dealerships, he earned commissions from the resulting sales.
Petitioner’s Forms W-2 for 1987, report income only from Crabtree
Hyundai, Inc., and Crabtree Toyota, Inc.4
4
The record in the instant case does not indicate how the
amount of referral commission was determined, or what the
mechanics were for petitioner to receive such a commission
without a Form W-2’s being issued by the dealership at which the
referred sale occurred. Respondent appears to agree that the two
Forms W-2 include all of petitioner’s commission income from the
Crabtree Dealerships and the related companies.
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