David A. and Paula J. Henderson - Page 1

                                 T.C. Memo. 2000-321                                  

                               UNITED STATES TAX COURT                                

                   DAVID A. AND PAULA J. HENDERSON, Petitioners v.                    
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 3863-98.                  Filed October 16, 2000.           

               David A. and Paula J. Henderson, pro se.                               
               Julie L. Payne, for respondent.                                        

                       MEMORANDUM FINDINGS OF FACT AND OPINION                        
               COHEN, Judge:  Respondent determined deficiencies of $10,830           
          and $5,807 in petitioners’ Federal income tax for 1994 and 1995,            
          respectively, and an addition to tax of $2,127 for 1994 under               
          section 6651(a)(1).  After concessions, the issue remaining for             
          decision is whether petitioners are entitled to deduct                      
          depreciation as a medical expense under section 213.                        

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