- 15 -
Finally, in passing, petitioner has mentioned that she
incurred significant medical expenses. Section 213(a), subject
to certain limitations, allows taxpayers a deduction for medical
expenses that are not compensated for by insurance or otherwise.
However, petitioner has not introduced any evidence to establish
the amount of her medical expenses for the years in issue.
Accordingly, we are unable to grant petitioner any relief from
the determined deficiencies in the form of a deduction for
medical expenses.
We conclude that, except as provided in respondent's
concessions, petitioner is not entitled to any relief from the
determined deficiencies. We reach this decision with some
reluctance, but note, as did the Supreme Court in Federal Crop
Ins. Corp. v. Merrill, 332 U.S. 380, 386 (1947), that "The
circumstances of this case tempt one to read the [regulations]
[and statutes] * * * with charitable laxity. But not even the
temptations of a hard case can elude the clear meaning of the
[regulations] [and statutes]."
To reflect the foregoing,
Decision will be entered
under Rule 155.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011