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(6) whether the person has the ability to vote the shares,
Yelencsics v. Commissioner, supra at 1528; Pacific Coast Music
Jobbers, Inc. v. Commissioner, supra at 874;
(7) whether the stock certificates are in the person’s
possession or are being held in escrow for the benefit of that
person, Pacific Coast Music Jobbers, Inc. v. Commissioner, supra
at 874;
(8) whether the corporation lists the person as a
shareholder on its tax returns, Feraco v. Commissioner, T.C.
Memo. 2000-312; Pahl v. Commissioner, T.C. Memo. 1996-176, affd.
150 F.3d 1124 (9th Cir. 1998);
(9) whether the person lists himself as a shareholder on
his individual tax return, Willie v. Commissioner, supra; Wilson
v. Commissioner, T.C. Memo. 1975-92, affd. 560 F.2d 687 (5th Cir.
1977);
(10) whether the person has been compensated for the amount
of income taxes due by reason of the person’s shareholder status,
Hightower v. Commissioner, T.C. Memo. 2005-274;
(11) whether the person has access to the corporate books,
Haskel v. Commissioner, T.C. Memo. 1980-243; and
(12) whether the person shows by his overt acts that he
believes he is the owner of the stock, Pahl v. Commissioner,
supra; Willie v. Commissioner, supra.
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Last modified: March 27, 2008