- 6 - Niesar Pahl. Petitioner’s duties, among other things, included supervising Niesar Pahl’s billing and payment procedures, establishing bank accounts, hiring and firing employees, and attending to the line of credit with the bank. Petitioner provided his own property as security for the line of credit with the bank. No other employees of Niesar Pahl who were not shareholders received a compensation package equivalent to what petitioner received. Among other items of compensation, petitioner received an annual salary of $180,000 and an automobile allowance of $6,500 (the automobile allowance). Petitioner’s receipt of the automobile allowance for 1990 is reflected on a Form 1099-MISC, Miscellaneous Income (the Form 1099), issued to petitioner for 1990 by Niesar Pahl and showing nonemployee compensation of $6,500. Petitioner’s Disassociation From Niesar Pahl On June 30, 1990, petitioner and Gosselin left Niesar Pahl. Petitioner and Gosselin departed pursuant to an agreement (the separation agreement). Pursuant to the separation agreement, Niesar Pahl transferred to petitioner and Gosselin furniture and equipment with an agreed value of $34,875 and assigned accounts receivable to them in the amount of $135,000. In consideration thereof, among other things, Pahl and Gosselin assumed Niesar Pahl’s credit line with the bank in the amount of $242,500, agreed that the June 30, 1990, employee payroll of $105,539 wouldPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011