Metro Leasing and Development Corporation - Page 13




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          condition of the dealerships was not made a part of the record.             
          There is no indication that the dealerships that leased or                  
          purchased from petitioner were in financial difficulty or that              
          petitioner’s income stream was in jeopardy.  Mr. Valente did, in            
          any event, play a role in obtaining and maintaining the source of           
          rental and interest income.  We must note, however, that Mr.                
          Valente received each year the use of a new automobile, monetary            
          compensation, and relatively large profit-sharing distributions             
          from the Green Valley Ford dealership.                                      
               For the years 1995 and 1996, approximately 68 percent and 78           
          percent, respectively, of petitioner’s income was from interest             
          and rents derived from sources that were established prior to or            
          at the beginning of the 1995 year.  The majority of the remainder           
          of petitioner’s income was derived from the sale of property,               
          both real and personal.  Other than the Valentes, petitioner had            
          only one employee, who was a clerical/bookkeeper.  Accordingly,             
          petitioner’s financial success and the job of ensuring a                    
          continued income stream fell upon the Valentes.  Although it was            
          not shown that the automobile dealerships to whom land had been             
          sold on installment contract or leased were in financial                    
          difficulty, petitioner has shown that, to some extent, Mr.                  
          Valente’s efforts helped to ensure or maintain the income stream.           
          Those same efforts also enhanced the capital structure of                   
          petitioner.  In these circumstances, it is difficult to decide              






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