- 4 - In 1994 and 1995, petitioner received compensation from the firm in the total amounts of $703,800 and $299,925, respectively, denominated by the firm as wages and independent contractor fees as follows: Petitioner’s Compensation Year Wages Fee Income Total 1994 $200,000 $503,800 $703,800 1995 200,000 99,925 299,925 In December of 1994, petitioner transferred back to the firm $129,000 which petitioner in 1994 had received from the firm as independent contractor fees. Initially, the firm’s bookkeeper classified the returned $129,000 as a reduction of the firm’s independent contractor fee expense account. However, in February of 1995, the law firm’s bookkeeper, for reasons unclear, reclassified the transfer from petitioner to the law firm of the $129,000 as a reduction in the firm’s accounts receivable due from petitioner. For the law firm’s taxable years ending November 30, 1994 and 1995, litigation costs were advanced by the firm relating to contingent fee contracts with its clients in the total amounts of $737,652 and $1,069,275, respectively. During the years in issue, certain office management tasks and all bookkeeping tasks of the firm were performed by a third party bookkeeper hired by petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011