Stephen D. Pahl and Louise A. Pahl - Page 2

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                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               HALPERN, Judge:  For petitioners’ taxable (calender) year              
          1990, respondent determined a deficiency in petitioners’ Federal            
          income tax liability of $28,694 and an accuracy-related penalty             
          of $371.                                                                    
               The issues remaining for decision are:  (1) Whether, during            
          1990, petitioner husband was a shareholder in an S corporation so           
          that petitioners are required to report his pro rata share of the           
          corporation’s income and certain other items, (2) whether                   
          petitioners failed to report $6,500 of nonemployee compensation             
          received by petitioner husband from the S corporation in 1990,              
          and (3) whether petitioners were negligent in filing their 1990             
          return.                                                                     
               Unless otherwise noted, all section references are to the              
          Internal Revenue Code in effect for the taxable year in issue,              
          and all Rule references are to the Tax Court Rules of Practice              
          and Procedure.                                                              
                                  FINDINGS OF FACT                                    
          Introduction                                                                
               Petitioners are husband and wife, who, for 1990, made a                
          joint return of Federal income tax liability.  Petitioners                  
          resided in Los Altos Hills, California, at the time the petition            
          in this case was filed.  Petitioner husband (hereafter,                     
          petitioner) is an attorney and member of the California bar.                





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