Stephen D. Pahl Louise A. Pahl v. Commissioner of Internal Revenue

BOOCHEVER, Circuit Judge:

The Tax Court denied the petition for re-determination of federal income taxes for tax year 1990 filed by Stephen Pahl and his wife, Louise. 1 The Tax Court concluded that in 1990 Stephen Pahl was a shareholder in the law firm Niesar, Pahl, Ceechini & Gosselin (the “firm”), a subchapter S corporation, and therefore Pahl should have reported a pro rata share of the law firm’s 1990 income on his tax returns. The Tax Court also determined that Pahl negligently failed to report as income a $6,500 automobile allowance from the firm, and thus is liable for taxes and a 26…