Stephen D. Pahl and Louise A. Pahl - Page 3

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          Niesar Pahl                                                                 
               Niesar, Pahl, Cecchini & Gosselin, A Professional                      
          Corporation (Niesar Pahl), a California corporation, was                    
          organized in January 1987.  Niesar Pahl was organized for the               
          practice of law.  On April 28, 1987, Niesar Pahl filed an                   
          election with the Internal Revenue Service to be treated as an              
          S corporation for Federal income tax purposes.  During 1990, and            
          at all other times here relevant, Niesar Pahl’s election to be              
          treated as an S corporation remained effective.  For 1990, Niesar           
          Pahl computed its taxable income on the basis of a calender year.           
               Niesar Pahl was known as Niesar, Pahl, Cecchini & Gosselin,            
          A Professional Corporation only from August 9, 1989, until                  
          sometime after June 30, 1990.  Immediately prior to that period,            
          Niesar Pahl was known as Niesar & Cecchini, and its only                    
          shareholders were Gerald V. Niesar and Garrett L. Cecchini.                 
          After that period, Niesar Pahl changed its name back to Niesar &            
          Cecchini.                                                                   
          Petitioner’s Association With Niesar Pahl                                   
               Prior to August 9, 1989, petitioner was not associated with            
          Niesar Pahl.  Sometime prior to August 9, 1989, petitioner and              
          another lawyer, Thomas Gosselin (Gosselin), agreed to become                
          shareholders, officers, and directors of Niesar Pahl as of                  
          August 9, 1989.  Petitioner and Gosselin each agreed to become              
          25-percent shareholders of the firm by purchasing 1,000 shares of           






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