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if you don't pay distributions proportionally, then the IRS will say the S-Corp had 2 classes of stock that is forbidden for S-Corps.  It would then treat your S-Corp as a C-Corp. the S-corp election is revoked and you can not re-elect for 5 years.  if it had income it will owe taxes. penalties and interest, In addition, instead of the distributions being treated as a return of capital, they will be taxable dividends.  

 

since distributions show up on the k-1 and the IRS will see that 50/50 owners did not get the same distributions, they might start an audit. you need to confer with a tax pro before you file that S-Corp return. even if you already filed it, consult a tax pro.