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petitioner, insurance paid for the cost of the medical care
provided by the clinic during 1995.
The printout is corroborating evidence that petitioner had
medical insurance and that he incurred some expense for medical
care during the year at issue. Accordingly, on the basis of the
record presented, and using our best estimate, we find that
petitioner is entitled to claim medical expenses of $592. See
Cohan v. Commissioner, supra. This expense is allowable as a
deduction to the extent that it exceeds 7.5 percent of
petitioner's adjusted gross income.
Issue 3. Child Care Expenses
Pursuant to section 21, petitioner reported child and
dependent care expenses of $4,800 for two children, and claimed a
credit of $1,056. Respondent disallowed the credit because
petitioner did not substantiate that the amounts were paid or
that petitioner had qualifying children.
Section 21(a) generally provides an allowance for a credit
against the tax to any individual taxpayer who maintains a
household that includes as a member one or more qualifying
individuals and who incurs employment-related expense. See Turay
v. Commissioner, T.C. Memo. 1999-315; Hopkins v. Commissioner,
T.C. Memo. 1992-326. The term "qualifying individual", under
section 21(b), includes a dependent of the taxpayer under the age
of 13 with respect to whom the taxpayer is entitled to a
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