Stephen T. Fan and Landa C. Fan - Page 12




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          consequently, the system does not qualify for the disabled access           
          credit.  Respondent’s determination in this regard is therefore             
          sustained.4                                                                 
               To reflect the foregoing,                                              


                                                  Decision will be                    
                                             entered for respondent.                  

























               4 Respondent also argues that the purchase of the intraoral            
          camera system was an unreasonable and unnecessary expenditure for           
          the purpose of making aurally delivered materials available to              
          hearing-impaired patients.  Sec. 44(c)(3).  Because we have                 
          determined that the system is not an “eligible access                       
          expenditure”, we do not address this issue.                                 





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