James Lewis and Lilian E. Hunter - Page 4

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          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             
               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                   

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