Ilija and Branka Mitic - Page 14




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            residence and the interior of that residence repainted.  On the                            
            instant record, we reject Mr. Mitic’s contentions that all of                              
            those expenditures “were approved and recommended” by Dr. Wolfe                            
            as expenditures from which Ms. Mitic “would benefit medically”                             
            and were “medically related” to Ms. Mitic’s asthmatic condition.                           
                  To support his contention regarding Dr. Wolfe, Mr. Mitic                             
            apparently relies on the June 27, 1980 letter from Dr. Wolfe.  We                          
            find Mr. Mitic’s reliance on that letter to be misplaced.  The                             
            June 27, 1980 letter was prepared over 13 years before the                                 
            expenditures in question were incurred.  We find that letter to                            
            have very little, if any, probative value regarding why petition-                          
            ers decided to remove carpeting from, and install hardwood                                 
            flooring in, their residence and have that residence repainted.                            
            In this connection, during 1993 and 1994, Ms. Mitic purchased                              
            tens of thousands of dollars’ worth of various items of furni-                             
            ture, rugs, and other decorator items that were placed in peti-                            
            tioners’ residence.  She purchased those items in an effort to                             
            begin an interior design activity that was based on the theory                             
            that petitioners’ residence was to be used as a showcase for                               
            prospective customers of that design activity.  On the record                              
            before us, we believe that it is more reasonable to conclude that                          
            the expenditures relating to the removal of carpeting, installa-                           
            tion of hardwood flooring, and painting throughout petitioners’                            
            residence were incurred primarily to accomplish Ms. Mitic’s                                






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