Shawn Michaels is president, secretary, treasurer, sole director, and sole shareholder of DXB, an S corporation real estate company. He manages all aspects of the company's operations, and he is the only person working at the company that holds a real estate broker's license. Shawn works 12-hour days and takes few days off. Corporate records indicate the following.

Year Gross Receipts Net Income

2016 $376,453 $122,605

2017 $405,244 $161,660

2018 $518,189 $231,454

Michaels and his wife, Kim, filed joint Federal income tax returns, but they did not report any wages or salaries on their returns. During 2018, Moon transferred $241,000 from DXB to his personal account. You are an expert witness for the IRS. Identify the items that you would present to the U.S. Tax Court with respect to the amount of Michaels' compensation that is subject to employment taxes and any other taxes due for 2018 (especially the additional Medicare net investment income tax). Hint: This is a reasonable compensation issue.