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1990 and before 1995, however, Mr. Valente’s reported wages did
not exceed $320,000 and were as low as $151,690 and averaged
$209,462. Mr. Valente consulted for and was compensated by Green
Valley Ford. He also consulted with the dealership executives in
connection with petitioner’s business operations. Mr. Valente
spent as much as 15 hours per week consulting. His expertise was
also used in connection with the South San Francisco property,
which also involved an automobile dealership. He consulted with
that dealership’s executives to help ensure their continued
ability to make mortgage payments on petitioner’s self-financed
sale of the property to the new dealer. Mr. Valente also spent a
limited amount of time working on petitioner’s accounts
collectible.
For 1995, petitioner deducted $240,435 as compensation to
officers, which included a yearend bonus of $180,435. For 1996,
petitioner deducted $460,000 as compensation to officers,
including yearend bonuses of $150,000 to Mrs. Valente and
$250,000 to Mr. Valente. For years prior to 1995, the Valentes
reported wages as follows:
Year Amount
1985 $498,647
1986 493,485
1987 1,053,801
1988 1,075,075
1989 941,407
1990 1,072,362
1991 320,000
1992 151,690
1993 152,851
1994 213,305
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