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function of the body. Sec. 213(d)(1)(A). As this Court stated
in Fischer v. Commissioner, 50 T.C. 164, 174 (1968):
The cases, the rulings, and the regulations make clear that
whether a service for which an expenditure is made
constitutes medical care will depend upon its therapeutic
nature to the individual, and not upon the title of the
person rendering the service, or whether the expense is
"medical" to all persons, or the general nature of the
institution in which the service is rendered. [Fn. refs.
omitted.]
This broad view of medical care allows medical expense deductions
for "nontraditional" medical care. Cf. Crain v. Commissioner,
T.C. Memo. 1986-138; Tso v. Commissioner, T.C. Memo. 1980-399.
More importantly, section 213 does not preclude deduction of
amounts expended for medical care even though such care was not
prescribed by a medical doctor.
But we are not persuaded on this record that the entire
amount in issue was expended only for the medical care of
Saundra. Using our best judgment, we allow petitioner to deduct
60 percent of the $3,018 or a total of $1,811 as medical expenses
under section 213 for the taxable year 1994. Cohan v.
Commissioner, 39 F.2d 540 (2d Cir. 1930).
Finally, we must decide whether petitioners are liable for
accuracy-related penalties for 1994 and 1995. Section 6662(a)
imposes an accuracy-related penalty in the amount of 20 percent
of the portion of an underpayment of tax attributable to
negligence or disregard of rules or regulations. Sec. 6662(a)
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