Robert and Martha Emanuel - Page 7




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          Income Tax Regs.  Expenses paid for transportation primarily for            
          and essential to the rendition of the medical care are expenses             
          paid for medical care, but the deductible amount does not include           
          the cost of meals and lodging while away from home receiving                
          medical treatment.  Sec. 1.213-1(e)(1)(iv), Income Tax Regs.                
               Deductions for expenditures for medical care allowable under           
          section 213 will be confined strictly to expenses incurred                  
          primarily for the prevention or alleviation of a physical or                
          mental defect or illness.  Sec. 1.213-1(e)(1)(ii), Income Tax               
          Regs.                                                                       
               Capital expenditures are generally not deductible.  Sec.               
          263; sec. 1.213-1(e)(1)(iii), Income Tax Regs.  However, a                  
          capital expenditure may qualify as a deductible medical expense             
          if it has as its primary purpose the medical care of the taxpayer           
          or his dependent.  Sec. 1.213-1(e)(1)(iii), Income Tax Regs.                
          Expenditures made for the operation or maintenance of a capital             
          asset may be deductible as medical expenses if they have as their           
          primary purpose the medical care, as defined in section 1.213-              
          1(e)(1)(i) and (ii), Income Tax Regs., of the taxpayer or his               
          dependent.  Sec. 1.213-1(e)(1)(iii), Income Tax Regs.                       
               A taxpayer is generally required to keep sufficient records            
          to enable the Secretary to determine the taxpayer’s correct                 
          income tax liability.  Sec. 6001; sec. 1.6001-1(a), Income Tax              
          Regs.  In addition, the taxpayer shall furnish the name and                 






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