Sean Moon is president, secretary, treasurer, sole director, and sole shareholder of Srreerz, 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 rakes few days off. Corporate records indicate the following.

Sean and his wife, Kim, filed joint Federal income tax returns, but they did nor report any wages or salaries on their returns. During 2019, Sean 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 Sean's compensation that is subject to employment taxes and any other taxes due for 2019 (especially the additional Medicare net investment income tax). Hint: This is a reasonable compensation issue

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Year Gross Receipts Net Income $376,453 $122,605 2017 405,244 518,189 2018 161,660 2019 231,454