(plaintiff, sole owner of S corporation CPA firm, paid a $24,000 salary and treated remaining $180,000 of annual income as S corporation K-1 income (not subject to FICA tax at 15.3 percent up to $106,800 (for 2010), and 2.9 percent Medicare tax on all income); plaintiff's motion for summary judgment denied - intent to pay compensation is to be determined based on a facts and circumstances test rather than self-serving assertions of proprietor; case arose based on examination into firm's potentially underpaid employment taxes).