- 7 - be funded from the credit line, and assumed certain accounts payable in the amount of $62,641. Niesar Pahl’s 1990 Return For 1990, Niesar Pahl filed Form 1120S, U.S. Income Tax Return for an S Corporation (Niesar Pahl 1990 return). Attached to the Niesar Pahl 1990 return are four Schedules K-1, Shareholder’s Share of Income, Credits, Deductions, Etc. One of those Schedules K-1 identifies petitioner as a shareholder (the petitioner K-1) and sets forth that petitioner’s pro rata share of certain items is as follows: (1) $95,969 of ordinary income from trade or business activities, (2) $236 of interest, and (3) $200 of charitable contributions. Petitioners’ 1990 Return Petitioners made their joint return of income tax liability for 1990 on Form 1040, U.S. Individual Income Tax Return (petitioners’ 1990 return). Petitioners’ 1990 return fails to include any of the items set forth on the petitioner K-1. Petitioners’ 1990 return was prepared by a paid tax return preparer, Clifford Fenske, Jr. OPINION I. Introduction We must decide three issues. First, we must decide whether, during 1990, petitioner husband (petitioner), an attorney, was a shareholder in Niesar, Pahl, Cecchini & Gosselin, A Professional Corporation (Niesar Pahl), a California corporation providingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
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