Pepi Schafler, f.k.a. Pepi Summer - Page 10

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          specialists recommended to her.  The record does not reflect the            
          amount paid by petitioner for this treatment, or the date on                
          which petitioner rendered the payment.  On July 8, 1992,                    
          petitioner was treated at Boston Orthopedic Group, Inc. (BOG), in           
          Brookline, Massachusetts.  Included in the expenses allowed by              
          respondent is a check in the amount of $125 written to BOG.                 
          Respondent did not allow petitioner to deduct any expenses with             
          respect to her treatment at Beth Israel.                                    
               The record reflects that petitioner incurred expenses for              
          transportation and lodging with respect to her stay in Boston               
          from July 4 to July 8, 1992.  To prove that she is entitled to              
          deduct her transportation expense, petitioner must establish that           
          her travel was "primarily for and essential to" her medical care.           
          Sec. 213(d)(1)(B).  We find credible petitioner's testimony,                
          corroborated by documents in the record, that she traveled to               
          Boston for the purpose of receiving medical treatment.                      
          Therefore, petitioner is entitled to deduct the cost of her                 
          transportation between Boston and Buffalo ($223).                           
               We now turn to the expenses claimed with respect to lodging.           
          To establish entitlement to expenses for lodging, a taxpayer must           
          prove that there is no significant element of personal pleasure,            
          recreation, or vacation in the travel.  Sec. 213(d)(2)(B).  In              
          addition, the taxpayer must prove that the travel was primarily             
          for and essential to medical care provided by a physician in a              
          licensed hospital (or a medical care facility which is related              



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