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petitioners failed to discuss this issue either at trial or on
brief, and offered no evidence with respect to this issue.
Accordingly, we sustain respondent's determination with
respect to the disallowed Schedule C deductions.
Medical Expenses
On their 1994 joint Federal income tax return, petitioners
claimed itemized deductions of $11,976 for medical and dental
expenses. Respondent made no adjustment to this amount in the
notice of deficiency. At trial, petitioners claimed they were
entitled to additional medical expenses in the amount of $6,490
for hearing aids.
Petitioners failed to raise this issue in either their
original or amended petitions. Furthermore, petitioners have
never requested leave to amend their pleadings. Petitioners had
ample time to file such a motion, and although petitioners are
pro se litigants, they are familiar with this Court's rules and
procedures. For example, on April 2, 1998, just 11 days before
trial, petitioners filed a motion for leave to file a second
amended petition in order to raise additional arguments. The
Court granted that motion on April 7, 1998. Petitioners did not
raise the issue of increased medical deductions in that motion,
but waited until the trial.
The purpose of the pleadings is to give the parties and the
Court fair notice of the matters in controversy and the basis for
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