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FINDINGS OF FACT
Some of the facts have been stipulated and are so found.2
The stipulated facts and the related exhibits are incorporated
herein by this reference. At the time of filing the petition in
this case, petitioners resided in Los Angeles, California.
James Lewis Hunter and his wife, Lillian E. Hunter, filed a
joint Federal income tax return for 1996. On Schedule A,
Itemized Deductions, of their return, petitioners claimed $10,530
in medical and dental expenses. The expenses included medical
and dental bills that petitioners paid on behalf of their
daughter.3 After accounting for the 7.5-percent adjusted gross
income (AGI) threshold limitation under section 213,4
petitioners’ medical and dental expense deduction equaled $2,227.
On their Schedule A, petitioners also claimed a $50,000
casualty loss for earthquake damage to the foundation of their
residence. After the threshold limitations under section
2 We note that petitioner Lillian E. Hunter did not sign
the stipulation of facts. Because petitioners have not argued
that the stipulation of facts does not apply to Mrs. Hunter, we
treat the stipulation of facts as applying to both Mr. Hunter and
Mrs. Hunter.
3 On the return, petitioners listed their daughter and her
two children as dependents. Respondent does not challenge these
dependency exemptions.
4 Sec. 213 provides that “There shall be allowed as a
deduction the expenses paid during the taxable year, not
compensated for by insurance or otherwise, for medical care of
the taxpayer, his spouse, or a dependent * * * to the extent that
such expenses exceed 7.5 percent of adjusted gross income.”
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