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couple of parcels of land and some stock, petitioner’s source of
income was from the remnants of Mr. Valente’s former ownership of
automobile dealerships. Until the beginning of 1995, they owned
realty that was leased to two different Ford dealerships. In the
beginning of 1995, they sold one of the properties to the lessee
and their income therefrom became income from seller-financing
rather than from rental.
Due to their age and physical condition, the Valentes were
essentially semiretired. During 1995 and 1996, Mr. Valente was
recuperating from surgery necessitated by prostrate cancer, so
that his ability to participate in petitioner’s business activity
was more limited than it had been in prior years. For the 4
years immediately prior to 1995 and 1996, the Valentes’ wages or
salary, including amounts received other than from petitioner,
averaged just over $200,000. For 1995 and 1996, the years under
consideration, petitioner compensated the Valentes in the amounts
of $240,435 and $460,000, respectively. We note that for 1995
and 1996, the Valentes were more hindered by health and age than
in prior years and unable to devote their full efforts to the
business.
Mr. Valente’s consultation to automobile dealerships which
either leased from petitioner or for whom petitioner was
mortgagor is thought by petitioner to be critical to the success
of the automobile companies. We are not able to find that Mr.
Valente’s role was critical, especially because the financial
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