Ronald and Judith Francis - Page 2

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          162(a).1  We hold that they are not entitled to deduct the                  
          medical expenses under section 162(a) because the compensation to           
          which the claimed deduction was attributable was not reasonable             
          in amount.  The second issue is whether $5,571 of the medical               
          expenses is 60 percent deductible under section 162(l).  We hold            
          that it is.                                                                 
                                  FINDINGS OF FACT                                    
               Some of the facts have been stipulated and are so found.               
          The stipulation of facts and accompanying exhibits are                      
          incorporated by this reference.  Petitioners resided in                     
          Pipestone, Minnesota, at the time they filed the petition.                  
               Petitioner Ronald Francis (Mr. Francis) has operated a farm            
          (the farm) as a sole proprietorship for 40 years.  Petitioner               
          Judith Francis (Mrs. Francis) assisted Mr. Francis by performing            
          farm chores, such as milking cows, since Mr. Francis began                  
          operating the farm.                                                         
               The farm established an employer-provided accident and                 
          health plan for employees (the plan) through an organization                
          called AgriPlan/BizPlan in 1991.  Eligible employees under the              
          plan would be fully reimbursed by the farm for health insurance             
          costs for themselves and their families and reimbursed up to                

               1All section references are to the Internal Revenue Code               
          effective for 2001, and all Rule references are to the Tax Court            
          Rules of Practice and Procedure, unless otherwise indicated.                
          Amounts are rounded to the nearest dollar.                                  





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