-2-
(collectively, S corporations) wholly owned by Frank Settimo
(petitioner) may deduct child care expenses incurred with respect
to petitioners’ children. We hold they may not. Section
references are to the Internal Revenue Code applicable to the
subject years. Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some facts are stipulated. We incorporate herein by this
reference the parties’ stipulations of fact and the exhibits
submitted therewith. We find the stipulated facts accordingly.
Petitioners are husband and wife, and they filed joint 2001 and
2002 Federal income tax returns. They resided in Linden,
Michigan, at all relevant times.
Petitioner started a window washing business (business) in
March 1994. His wife began working in that business 2 years
later. In June 1997, petitioner began hiring other individuals
to work in the business. In 2001, petitioner conducted the
business through his wholly owned S corporation, Professional
Window Cleaning, Inc. (PWC). Petitioner terminated PWC as of the
start of 2002 and began conducting the business through a second
wholly owned S corporation, Algimarso Glass Cleaners, Inc. (AGC).
For Federal income tax purposes, petitioner reported the income
and expenses of the S corporations using the cash receipts and
disbursements method.
Page: Previous 1 2 3 4 5 6 Next
Last modified: May 25, 2011