- 3 - petitioner’s accounts receivable were deposited in the Seafirst account. Kovacevich worked 160 to 180 hours per month for petitioner and performed all services necessary to generate gross receipts on behalf of petitioner, including: Paying creditors, hiring employees, signing checks, determining employee compensation, renewing petitioner’s malpractice insurance, and signing petitioner’s Federal tax returns. No other person performed legal services on behalf of petitioner. Kovacevich received funds from petitioner as his needs arose and was not compensated for his services at predetermined intervals. In 1994 and the first quarter of 1995, respectively, petitioner paid Kovacevich $132,000 and $33,250. Petitioner issued checks to Kovacevich, his wife, and their creditors (e.g., Nordstrom, Teneff Jewelry, Fit and Hollywood, and National Golf), and Kovacevich informed petitioner’s accountant and tax return preparer, Bob Moe & Associates (Moe), that the payments were draws. Petitioner classified the payments as “loans” on its corporate ledgers and did not file Forms 1099-MISC, Miscellaneous Income, relating to the payments. Petitioner also paid Kovacevich’s law license renewal fees, office expenses, bar dues, and health insurance premiums and deducted most of these expenses on its corporate income tax returns.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011