Margaret M. Merker - Page 15

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               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.                               










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