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4 . P , an S corporation, distributed its entire $ 5 0 0 , 0 0 0 net business income to John, its sole
P an S corporation, distributed its entire $ net business income to John, its sole shareholder and president. John then reported this $ as nonpassive income from an S corporation on his Form
John performs substantial services for P He spent at least hours per week providing consulting services on behalf of P
John is the only person working for P All of Ps income was generated from the consulting services provided by John.
P did not make regular payments to John; rather, John withdrew money from Ps bank account at his discretion.
Requirements: After conducting appropriate research, answer the following questions and include citations from relevant tax authorities:
a Is an S corporation required to pay income tax?
b Based on the information provided, is John considered an employee of the S corporation?
c What are the tax differences between income distributions and salary payments in an S corporation?
d P treated all $ of net income as a distribution to its sole shareholder, John. Do you agree that the entire $ should be treated as a distribution? What motivated P to classify the entire $ as a distribution?
e Cite at least one tax court case similar to this situation.
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