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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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Last modified: May 25, 2011