Frank M. Settimo and Sallyn M. Settimo - Page 6

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          S corporations.1  Indeed, the only individuals whose children’s             
          daycare expenses were paid by the S corporations were the sole              
          owner of the S corporations and his wife.                                   
               We hold for respondent.  We have considered all arguments in           
          this case and consider those arguments not discussed above to be            
          without merit.  To reflect issues settled by the parties,                   


                                                  Decision will be entered            
                                             under Rule 155.                          






















               1 Nor have petitioners shown that the primary beneficiary of           
          the payments was either S corporation.  See Hood v. Commissioner,           
          115 T.C. 172, 179 (2000).                                                   





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