Peter Milton Joseph and Ella Joseph, Deceased - Page 9

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          as previously noted, was diagnosed with Parkinson’s disease in              
          approximately 1980.  However, petitioners have provided no                  
          substantiation that such expenses were incurred.  At trial,                 
          petitioner did not testify as to any medical expenses that were             
          incurred during taxable year 1999.  Petitioner did not submit any           
          evidence either before, during, or after trial that would prove             
          any medical expenses were incurred during taxable year 1999.                
               Upon the basis of the record and because petitioners have              
          failed to provide any substantiation to support their claimed               
          deduction for medical and dental expenses, we find that we cannot           
          estimate any amounts of petitioners’ deduction under the Cohan              
          rule, and we sustain respondent’s disallowance of petitioners’              
          claimed deduction for medical and dental expenses in the amount             
          of $21,358.  Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.             
          2.   Real Estate Taxes                                                      
               Petitioners claimed a Schedule A deduction for real estate             
          taxes paid during taxable year 1999 of $3,456 on their Federal              
          income tax return.  Respondent agrees that petitioners are                  
          entitled to deduct, under section 164, $1,017 of the claimed                
          Schedule A deduction for real estate taxes.  However, respondent            
          contends that petitioners are not entitled to the additional                
          $2,439.  Respondent determined that petitioners did not prove               
          that the claimed real estate taxes were incurred or, if incurred,           
          that they were paid during taxable year 1999.                               






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