- 12 - 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 financialPage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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