- 4 -
6001; Hradesky v. Commissioner, 65 T.C. 87, 89-90 (1975), affd.
per curiam 540 F.2d 821 (5th Cir. 1976); sec. 1.6001-1(a), Income
Tax Regs. To substantiate medical and dental expenses under
section 213, the taxpayer must furnish the name and address of
each person to whom payment was made and the amount and date of
each such payment. See sec. 1.213-1(h), Income Tax Regs. If
requested by the Commissioner, the taxpayer must also furnish an
itemized invoice which identifies the patient, the type of
service rendered, and the specific purpose of the expense. See
id.
Respondent disallowed the $5,704 in medical and dental
expenses on the ground that petitioners had failed to provide
adequate documentation substantiating these expenses.
Petitioners, however, argue that they substantiated these
expenses with canceled checks that they wrote to their daughter.
According to Mr. Hunter’s testimony, their daughter used these
checks to pay for her and her children’s medical and dental
expenses. Petitioners, however, have failed to provide any of
the canceled checks or other documents relating to these
expenses.7 We are not obligated to accept Mr. Hunter’s self-
7 The Court decided to recall the case during the second
week of the trial session so petitioners could locate and submit
any documents which could be used to substantiate the disallowed
medical and dental expenses. However, at the recall, petitioners
failed to appear and produce any canceled checks, receipts,
invoices, or other documentation verifying the disallowed
expenses.
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