Metro Leasing and Development Corporation - Page 4




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               During the years in issue, petitioner had three employees,             
          Mr. and Mrs. Valente and Jo Ann Michaels, who was the corporate             
          secretary and bookkeeper.  As bookkeeper, Ms. Michaels deposited            
          receipts, prepared checks, reconciled bank statements and                   
          maintained the books of account, including the general ledger and           
          the cash receipts and disbursement journals. Petitioner’s place             
          of business was in the Valentes’ residence.                                 
               Petitioner’s business during 1995 and 1996 included the                
          ownership of land and buildings leased to Green Valley Ford,                
          under which the lessee paid the expenses associated with the                
          property.  Petitioner was also engaged in the business of leasing           
          automobiles and the purchase and sale of real property.                     
          Petitioner had approximately 10 automobile leases during the                
          years in question, all of which had been entered into prior to              
          1995.  Petitioner’s assets included land and a building in El               
          Cerrito, and mortgages receivable in excess of $2.5 million,                
          secured by real property located on Airport Boulevard, South San            
          Francisco.  Petitioner had sold this property, on the installment           
          basis, on January 19, 1995.                                                 
               Mr. Valente was qualified to be involved in any aspect of              
          the automobile business, including petitioner’s activities of               
          leasing realty to an automobile dealer and leasing automobiles.             
          Mr. Valente was, in general, successful and experienced in                  
          business operations.  For the 12-year period 1985 through 1996,             
          his highest annual wages exeeded $1 million, and his average                
          wages for that period exceeded one-half million dollars. After              



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