Paul F. Dickie - Page 10




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               The parties stipulated that petitioner paid Natural Wellness           
          $3,018.29 with 11 checks in 1994, which were put in evidence.               
          Petitioner explained that this amount represented the cost of               
          consultations and dietary supplements.  Petitioner testified that           
          Natural Wellness was operated by Frank Charles, a "naturopathic             
          doctor" who practiced in Excelsior, Minnesota.  Naturopathy is a            
          system of treatment of disease emphasizing assistance to nature             
          and sometimes including the use of natural medical substances               
          such as herbs, vitamins, and salts, and certain physical means,             
          such as manipulation and electrical treatment.  Webster's Third             
          New International Dictionary 1508 (unabridged) (1993).                      
               Respondent argues that because the treatments provided                 
          through Natural Wellness were not prescribed by a medical doctor,           
          and were not covered by an insurance company, the payments for              
          such treatments are not deductible under section 213. Respondent            
          on brief states that "it is reasonable to assume that the                   
          insurance company's refusal to pay for [Charles'] treatments                
          reflects their [sic] informed opinion that his methods were not             
          suitable or effective in the treatment of cancer."                          
               We disagree with respondent's position.  The deductibility             
          of medical care payments under section 213 is not strictly                  
          limited to traditional medical procedures, but it includes                  
          payments made for the purpose of affecting any structure or                 







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