Sean Moon is president, secretary, treasurer, sole director, and sole shareholder of Streetz, 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
2016 ......................... $376,453 ..................... $122,605
2017 ......................... 405,244 ......................... 161,660
2018 ......................... 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 2018, Moon transferred $240,000 from Streetz 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 Moon's compensation that is subject to employment taxes and any other taxes due for 2018 (especially the additional Medicare net investment income tax)?