(plaintiff, partnership CPA firm (established as separate S corporations for each partner in firm with each S corporation paying salary to each shareholder in firm), paid CPA-owner $24,000 in annual salary out of CPA's approximately $200,000 in earnings for 2002 and 2003 from CPA business; $67,044 of distributions reclassified as salary each year resulting in $91,044 of FICA/Medicare wages; salary paid unreasonably low - taxpayer, as shareholder paid less than rookie accountant in firm).