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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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