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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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