- 4 - Petitioner has been the sole shareholder of the company since 1991, and president and treasurer since approximately 1988. Petitioner had significant pass-through income from the company and received distributions from the company for all taxable years in issue in the instant case. Petitioner’s certified public accountant, Jon Mazer (Mr. Mazer), has prepared all the corporate income tax returns for the company, including those for 1999 through 2002. Prior to 1999, Mr. Mazer also prepared individual income tax returns for petitioner. Petitioner reviewed, signed, and filed all the Forms 1120S, U.S. Income Tax Return for a Subchapter S Corporation, for the company for all taxable years in issue. When petitioner filed the Forms 1120S for the company for taxable years 1999 through 2002 he was aware of the net income reported on those returns. Petitioner understood the tax effects of having an S corporation and specifically was aware during the taxable years in issue that the net profits from an S corporation are passed through and taxable to its shareholders. Prior to the 1999 taxable year, petitioner reported the net income of the company on his individual income tax returns. Petitioner told Mr. Mazer not to prepare petitioner’s individual income tax returns starting with the 1999 taxable year. Petitioner, however, still had Mr. Mazer prepare the FormsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011