Ronna Joan Robertson - Page 6




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               A.  Medical and Dental Expenses                                        
               Section 213(a) permits a deduction for expenses paid during            
          the taxable year for medical care of the taxpayer, his or her               
          spouse, or a dependent (as defined in section 152), to the extent           
          such expenses exceed 7.5 percent of adjusted gross income and to            
          the extent such expenses are not compensated for by insurance or            
          otherwise.                                                                  
               Petitioner claims that she is entitled to medical expense              
          deductions of $1,501.74 and $631.14 for the 1993 and 1994 taxable           
          years, respectively.  During 1993 and 1994, petitioner maintained           
          a joint bank account at First Interstate Bank with her mother,              
          Joanne Robertson, and her sister, Alexandra Robertson.                      
          Petitioner submitted into evidence numerous canceled checks from            
          this joint bank account payable for medical and dental expenses             
          in 1993 and 1994.  For the years in issue, only one check--check            
          number 8390, dated October 14, 1993, in the amount of $42--bears            
          petitioner’s signature.  The remainder of the checks submitted by           
          petitioner bear the signature of either petitioner’s mother or              
          petitioner’s sister, a strong indicator that these payments were            
          not made for expenses incurred by petitioner.4                              




               4 While deductions are permitted for medical expenses paid             
          for a dependent, petitioner has not produced any evidence that              
          her mother or her sister was her dependent during the taxable               
          years at issue.                                                             





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