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bound by the actions or inactions of respondent with respect to
medical expense deductions claimed by petitioners for years prior
to 1993.
Mr. Mitic also contends that petitioners are entitled to
petitioners’ claimed medical expense deduction at issue for 1993
because the expenditures in question (1) “were approved and
recommended [by] Dr. James Wolfe” as expenditures from which Ms.
Mitic “would benefit medically” and (2) “were reasonable and
medically related to wife’s [Ms. Mitic’s] chronic asthma condi-
tion.” Those contentions are not supported by the record in this
case. Even if they were, on the record before us, we find that
Mr. Mitic has failed to prove that the expenditures in question
qualify under section 213 and the regulations thereunder as
deductible expenses for the medical care of Ms. Mitic.
We consider first the rental expense incurred by petitioners
while the carpeting was removed from, and the hardwood flooring
was installed in, petitioners’ residence and the interior of that
residence was repainted. On the record before us, we find that
Mr. Mitic has failed to show that Dr. Wolfe approved and recom-
mended that rental expense and that it qualifies as an expense
paid for medical care under section 213. See sec. 213(d)(2).
We turn now to the remaining expenditures in question
consisting of the amounts paid by petitioners to have the carpet-
ing removed and hardwood flooring installed throughout their
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