T.C. Memo. 1996-176 UNITED STATES TAX COURT STEPHEN D. PAHL AND LOUISE A. PAHL, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 7757-94. Filed April 11, 1996. Petitioner husband (P), an attorney, claims that he was not a shareholder in an S corporation organized for the practice of law. P did not report any of the income and other items of the S corporation; he also received an item of nonemployee compensation from the S corporation, which he claimed he did report. 1. Held: P was a shareholder of the S corporation for the taxable year in issue and must report his pro rata share of the income and other items of the S corporation. 2. Held, further, P failed to report the nonemployee compensation. 3. Held, further, R’s imposition of an accuracy- related penalty for negligence under sec. 6662, I.R.C., is sustained. Stephen D. Pahl, for petitioners. Alan D. Hill, for respondent.Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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