Metro Leasing and Development Corporation - Page 3




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          concerned about his condition, so he appointed his wife, Lena               
          Valente, to be petitioner’s president during the years under                
          consideration.  During 1995 and 1996, Mrs. Valente was 66 and 67            
          years of age, respectively.  Even though he was ill, Mr. Valente            
          remained active in petitioner’s business by means of a                      
          cooperative effort with Mrs. Valente.  Under that arrangement,              
          Mr. Valente was the decision-maker, and Mrs. Valente executed his           
          decisions.  Mr. Valente determined the amount of compensation to            
          be paid to officers based on the profitability of the business.             
          Because of their joint efforts, Mr. and Mrs. Valente’s                      
          compensation was treated as an undivided amount for their                   
          combined efforts.  Mrs. Valente became ill during 1996, retiring            
          at the end of that year, and she died during 1998.                          
               Mr. Valente became involved in the automobile business in              
          1959 and at one point owned seven automobile dealerships and an             
          automobile leasing company.  Mr. Valente sold the last of his               
          automobile dealerships, Green Valley Ford, in 1990.  In                     
          connection with the last sale, Mr. Valente agreed to provide                
          business consultation to the new owners and to “run” the profit-            
          sharing plan.  The new owners agreed to provide the Valentes with           
          a new car each year. In 1991, Mr. Valente received $20,444 of               
          compensation from Green Valley Ford and for 1992, 1993, 1995, and           
          1996 he received $1,690, $2,851, $3,289, and $2,049,                        
          respectively.  For 1995 and 1996, Mr. Valente received                      
          distributions of $55,307 and $76,076, respectively, from Green              
          Valley Ford’s profit-sharing plan.                                          



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