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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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