Tae M. Kim and Young J. Kim - Page 14




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          find that petitioners have failed to substantiate the business              
          purpose of petitioner wife's claimed expenses.  We hold that                
          petitioners are not entitled to any deductions for 1993 for                 
          petitioner wife's claimed expenses.                                         
               The second issue for decision is whether petitioners are               
          entitled to a medical expense deduction for 1993 in excess of the           
          amounts allowed and conceded by respondent.                                 
               On a Schedule A attached to their 1993 return, petitioners             
          claimed medical expenses in the amount of $10,668.36.  After                
          accounting for the section 213(a) limitation, petitioners claimed           
          a medical expense deduction for 1993 in the amount of $7,032.51.            
          In the statutory notice of deficiency, respondent determined that           
          petitioners did not establish that they paid more than $8,978 for           
          medical expenses during 1993.  Respondent allowed petitioners a             
          medical expense deduction in the amount of $3,724, after                    
          accounting for his adjustments to their adjusted gross income and           
          the section 213(a) limitation.3  At trial, respondent conceded              
          that petitioners are entitled to deduct an additional $20 of                
          medical expenses.  This concession leaves $1,670.36 of the                  
          claimed medical expenses in issue, which approximates the amount            



          3         Respondent's adjustments to petitioners' medical                  
          expense deductions for 1993 and 1994, to the extent based on his            
          adjustments to petitioners' adjusted gross income and sec. 213              
          limitations for 1993 and 1994, are computational and will be                
          resolved by the Court's holding on the first issue in this case.            




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