Benigno Antonio Gasparutti - Page 5

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          payment for medical expenses was made and the amount and date for           
          each such payment.  Moreover, the taxpayer must be prepared to              
          substantiate any claimed deductions by furnishing statements or             
          itemized invoices from the individual or entity to which payment            
          for medical expenses was made.  These statements or invoices                
          should indicate the nature of the service rendered and to or for            
          whom rendered.  Blackburn v. Commissioner, T.C. Memo. 1982-529;             
          sec. 1.213-1(h), Income Tax Regs.                                           
               Petitioner testified that some of his medical documents were           
          taken by the landlord when he was evicted.  Although the Court              
          informed petitioner that evidence was needed to prove the amounts           
          claimed, petitioner also stated that he did not wish to provide             
          any documents regarding his medical condition because it is an              
          invasion of his privacy.  Petitioner has failed to meet the                 
          substantiation requirements provided by section 1.213-1(h),                 
          Income Tax Regs.  Without any evidence of medical expenditures,             
          respondent is sustained on this issue.                                      
               b. Taxes                                                               
               Section 275(a)(1)(A) expressly provides that no deduction              
          shall be allowed for Federal Social Security taxes levied on                
          employees.7  Section 164(a) provides for the deduction of (1)               

          7  SEC. 275.  CERTAIN TAXES.                                                
               (a) General Rule.--No deduction shall be allowed for the               
          following taxes:                                                            

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