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promoted a sales administrator to sales manager in mid-1996--
Jack has always held these positions.
In his capacity as general sales manager, Jack oversaw
petitioner’s daily sales operations, worked with salespeople on
all transactions, appraised trade-ins, negotiated with buyers,
and approved all closings. In his capacity as advertising
manager, Jack directed petitioner’s advertising efforts: He met
with all media, wrote ad copies for television, radio, and
newspaper advertisements, prepared the advertising budgets, and
approved all advertising costs. In his capacity as loan officer,
Jack approved the underwriting for all in-house loans and
personally worked delinquent accounts. In his capacity as
licensed general insurance agent, Jack was responsible for
petitioner’s book of insurance; petitioner had more than 400
insurance customers. Petitioner insured 60 percent of its sales.
The commissions earned for Jack’s work as the licensed general
insurance agent went to petitioner and were reported on
petitioner’s tax return. As the personnel manager, Jack was
responsible for hiring, firing, supervising, training, and
evaluating all of petitioner’s employees. In his capacity as
purchasing officer, Jack ordered all of petitioner’s inventory,
lot supplies, and office supplies. He also bought all company
vehicles and approved all invoices for payment. In his capacity
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Last modified: May 25, 2011