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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

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 Moon's compensation that is subject to employment taxes and any other taxes due for 2016.

Sean Moon is president, secretary, treasurer, sole director and sole shareholder of Streez, 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. Sean works 12-hour days and takes few days off. Corporate records indicate the following:

Year Gross Receipts Net Income
2014 $376,453 $122,605
2015 $405,244 $161,660
2016 $518,189 $231,454

Moon and his wife, Kim filed joint Federal income tax returns, but they did not report any wages or salaries on their returns. During 2016, Moon transferred $240,000 from Streetz to his personal account.

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