- 3 - A. Wiley L. Barron, CPA, Ltd. Wiley L. Barron, CPA, Ltd. (petitioner) is an S corporation that was formed on or about January 2, 1990. Since the date of its inception, petitioner has been engaged in the business of providing accounting services. Wiley L. Barron (Mr. Barron) is, and has been for many years, a certified public accountant (C.P.A.). Mr. Barron is petitioner’s president and sole shareholder, and he is the only C.P.A. who performs services for petitioner. The only other individuals who perform services for petitioner are two employees who provide clerical and support services.2 As petitioner’s president, Mr. Barron exercises exclusive authority over all of petitioner’s affairs. He is solely responsible for making management decisions and for controlling and directing every facet of petitioner’s business. B. Petitioner’s Income Tax Returns Petitioner filed Form 1120S (U.S. Income Tax Return for an S Corporation) for each of the calendar years 1994, 1995, and 1996. On Schedule M-2 of these returns, petitioner reported distributions other than dividend distributions in the following amounts: 2 The status of these two service providers as employees of petitioner is not in issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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