Second District Looks at Zold

Zold v. Zold was reviewed and followed, albeit by a case with a final hearing predating the opinion, in the first portion of the Wamsley v. Wamsley decision out of the Second. While Zold, however, would squarely place the burden on the party claiming a lack of income passing through an S Corp, Wamsley seems to identify where the burden shifts to the other party to disprove the allegations…