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PAHL v. C.I.R.

No. 96-70402.

150 F.3d 1124 (1998)

Stephen D. PAHL; Louise A. Pahl, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 29, 1998.

Attorney(s) appearing for the Case

Stephen D. Pahl, Pro se, San Jose, California; Thomas M. Gosselin, Pahl & Gosselin, San Francisco, California, for petitioners-appellants.

Bruce R. Ellisen and Annette M. Wietecha, United States Department of Justice, Tax Division, Washington, DC, for respondent-appellee.

Before: D.W. NELSON, BOOCHEVER, and REINHARDT, Circuit Judges.

BOOCHEVER, Circuit Judge:

The Tax Court denied the petition for redetermination 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, Cecchini & 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...

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