Yes, the CPA would have known, and should have made sure it was done correctly. It's actually common for owners of small S corps to not pay themselves a salary. (The fact that it's widespread is why the IRS is up in arms about it.) CPAs have varying degrees of tolerance for it. Some CPAs will advise the client to do it right, but will prepare the return even if there's no salary. Some will badger the client more forcefully. Some will simply refuse to do the return if the client didn't take a reasonable salary. Not all CPAs, and even CPA firms, are totally honest.
