- 11 - to, or the equivalent of, a licensed hospital). Sec. 213(d)(2)(A). Although we have concluded that petitioner traveled to Boston with the primary motive of receiving medical care, the record reflects that petitioner received medical treatment at a licensed hospital on July 7, 1992, and orthopedic treatment on July 8, 1992, while the expenses in issue concern lodging from the night of July 4 through July 7, 1992. On the basis of the record before us, we conclude that two of the four nights' lodging were essential to petitioner's medical care. Accordingly, we will allow petitioner to deduct expenses for lodging in the amount of $100, attributable to lodging for two nights at a rate of $50 per night. See sec. 213(d)(2) (limiting deduction for lodging to $50 per night). With respect to petitioner's claims for the expenses relating to her treatment at Beth Israel Hospital in Boston, petitioner has offered no evidence of the amount and date of any payment for such services. Petitioner, therefore, has failed to meet the substantiation requirements provided by section 1.213- 1(h), Income Tax Regs. Furthermore, we are unsure as to whether the cost of this treatment was covered in whole or in part by petitioner's health insurance. See Cooper v. Commissioner, T.C. Memo. 1987-334. Therefore, we conclude that petitioner is not entitled to any deduction for expenses related to her treatment at Beth Israel Hospital.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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