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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.
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