Kenneth & Linda J. Logie - Page 7

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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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