John M. and Carolyn Merritt - Page 4

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               In 1994 and 1995, petitioner received compensation from the            
          firm in the total amounts of $703,800 and $299,925, respectively,           
          denominated by the firm as wages and independent contractor fees            
          as follows:                                                                 

                Petitioner’s Compensation                                             
          Year        Wages        Fee Income      Total                              
          1994      $200,000            $503,800     $703,800                         
          1995       200,000          99,925      299,925                             

               In December of 1994, petitioner transferred back to the firm           
          $129,000 which petitioner in 1994 had received from the firm as             
          independent contractor fees. Initially, the firm’s bookkeeper               
          classified the returned $129,000 as a reduction of the firm’s               
          independent contractor fee expense account.  However, in February           
          of 1995, the law firm’s bookkeeper, for reasons unclear,                    
          reclassified the transfer from petitioner to the law firm of the            
          $129,000 as a reduction in the firm’s accounts receivable due               
          from petitioner.                                                            
               For the law firm’s taxable years ending November 30, 1994              
          and 1995, litigation costs were advanced by the firm relating to            
          contingent fee contracts with its clients in the total amounts of           
          $737,652 and $1,069,275, respectively.                                      
               During the years in issue, certain office management tasks             
          and all bookkeeping tasks of the firm were performed by a third             
          party bookkeeper hired by petitioner.                                       







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