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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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