John Paul Massa - Page 2




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               Respondent determined a deficiency in petitioner's Federal             
          income tax for 1992 in the amount of $5,115 and an addition to              
          tax pursuant to section 6651(a)(1) in the amount of $1,279.                 
               The issues for decision are:  (1) Whether petitioner is                
          entitled to Schedule C trade or business expense deductions; (2)            
          whether petitioner is entitled to a medical expense deduction for           
          amounts claimed for his special diet; and (3) whether petitioner            
          is liable for the section 6651(a)(1) addition to tax.2                      
               Some of the facts have been stipulated and are so found.               
          The stipulations of fact and attached exhibits are incorporated             
          herein by this reference.  Petitioner resided in Colorado                   
          Springs, Colorado, on the date the petition was filed in this               
          case.                                                                       
               Petitioner is a certified public accountant.  He worked as             
          the chief financial officer of Gates Land Company (GLC) until he            
          retired in 1989.  At that time, GLC was downsizing its workforce            
          and petitioner was suffering from complications related to                  
          Crohn's disease.  Crohn's disease is characterized by                       
          inflammation of the lower digestive tract.  Petitioner has                  
          endured numerous surgeries and periods of hospitalization for his           
          Crohn's disease.  In order to meet his minimum nutritional                  
          requirements, petitioner has followed a special diet and has                

          2         Respondent's adjustments to petitioner's taxable Social           
          Security benefits, medical expense deduction (other than to the             
          amounts claimed for his special diet), and miscellaneous itemized           
          deductions are computational and will be resolved by the Court's            
          holding on the issues in this case.                                         



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