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We sustain respondent in full with respect to this issue. See
Finesod v. Commissioner, T.C. Memo. 1994-66.
2. Issue Two
We decide whether petitioner may deduct certain itemized
deductions that respondent disallowed. Petitioner reported these
deductions on her 1989 and 1990 Schedules A, Itemized Deductions.
Petitioner’s 1989 Schedule A reports the following itemized
deductions: $600 in interest, $2,750 of contributions by cash or
check, $490 of contributions by other than cash or check, and
$5,760 of “miscellaneous deductions” (before the application of
the 2-percent floor). Petitioner claims a deduction for
miscellaneous deductions, net of the 2-percent floor.
Petitioner’s 1990 Schedule A reports the following itemized
deductions: $3,616 of medical expenses (before application of
the 7.5-percent floor), $1,700 of interest, $2,700 of
contributions by cash or check, $490 of contributions by other
than cash or check, and $5,900 of “miscellaneous deductions”
(before the application of the 2-percent floor). Petitioner
claims deductions for medical expenses and miscellaneous
deductions, after reducing her reported amounts by the applicable
floors.
Respondent determined that petitioner’s 1990 medical
deduction was $52, instead of the larger amount claimed by
petitioner, because of the increase in her adjusted gross income
on account of the above-mentioned adjustments to her 1990
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