Stephen D. Pahl and Louise A. Pahl - Page 7

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          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 providing               




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