Metro Leasing and Development Corporation - Page 12




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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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