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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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