The Tax Court held that W-2 wages paid by two S corporations that were not deductible under Sec. 280E in computing their taxable income could not be taken into account in calculating the Sec. 199A ...

And in computing that 199A deduction, they included all the wages they had paid in their W-2 wage limit, and the IRS said, "No can do." If the wages are not deductible, they shouldn't be in your W-2 ...