-4-
service with a check drawn on the bank account of PWC or AGC.
For the subject years, PWC and AGC claimed deductions of $1,288
and $4,800, respectively, for the daycare expense of petitioners’
children.
OPINION
We decide the single issue mentioned above. In that we find
that the facts underlying our decision of that issue are not in
dispute, we decide that issue without regard to which party bears
the burden of proof. The parties dispute two other issues in
addition to the one that we decide. The first other issue
concerns the amount of wages that petitioner failed to report for
2001 and 2002. The second other issue concerns whether all of
the S corporations’ workers are their employees. We do not
decide either of those two other issues in that our decision of
those issues is unnecessary to our redetermination of
petitioners’ Federal income tax deficiencies for the subject
years. As to the first other issue, petitioner is the sole
shareholder of the S corporations, and any amount of wages that
he failed to report on his 2001 and 2002 Federal income tax
returns will be offset entirely by the corresponding increase in
the deduction that passes through to him from the S corporations.
See Griffin v. Commissioner, T.C. Memo. 1995-246. As to the
second other issue, that issue also does not affect our
redetermination of petitioners’ deficiencies.
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