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claimed under section 213 by furnishing the name and address of
each person to whom payment for medical expenses was made and the
amount and date for each payment. See sec. 1.213-1(h), Income
Tax Regs. Moreover, the taxpayer must be prepared to
substantiate any claimed deductions by furnishing statements or
itemized invoices from the individual or entity to which payment
for medical expenses was made. These statements or invoices
should indicate the nature of the services rendered, and to or
for whom rendered. See id.
At trial, petitioner testified that he could not remember
the name or the cost of the medical devices. Furthermore,
petitioner testified that the more expensive of the two devices
may have cost as much as $500; however, in his reconstruction of
costs, petitioner represented that the combined cost of the two
devices was $2,712. Clearly, if the more expensive device was
$500, the total cost of both devices must be substantially less
than the amount petitioner represented he paid in his
reconstruction.
Petitioner had no receipt or other evidence to substantiate
the date of purchase or cost of either device. He testified that
he had no receipt for the more expensive device because it was
actually purchased by someone else who was able to buy it at a
discount. Petitioner did not call that person as a witness to
testify as to the details of the transaction. We cannot assume
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