Pepi Schafler, f.k.a. Pepi Summer - Page 11

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          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.                                                    



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