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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
David A. and Paula J. Henderson (petitioners) resided in
Medical Lake, Washington, when their petition was filed.
Petitioners’ son, Bradley, suffers from spina bifida and is
confined to a wheelchair.
In 1991, petitioners purchased a van for the sole purpose of
transporting Bradley. The purchase price of the van was
approximately $26,000. In 1992, Bradley’s physician believed
that, due to Bradley’s increasing weight and size and his
prolonged medical condition, a wheelchair lift was necessary.
Petitioners modified the van specifically for Bradley’s medical
needs by installing an automatic wheelchair lift and raising the
roof of the van. Such modifications cost petitioners an
additional $4,406.
During 1994 and 1995, petitioners lived in eastern Oregon
and, on a weekly basis, transported Bradley to and from hospitals
and doctors’ appointments in Spokane and Seattle, Washington.
The specially modified van was the only means of transportation
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Last modified: May 25, 2011