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The 7.5 percent of adjusted gross income limitation pursuant to
section 213(a) reduced this amount by $3,771 so that the net
medical expense deduction was $6,429.
On their 1996 return, petitioners also listed on Schedule A
the following amounts as job expenses:
Business meals $2,500
Out of town meals 700
Fuel 1,000
Repairs/maintenance 1,800
Insurance 2,500
Wash/wax/misc. 200
Tax preparation fees 200
Work wear/shoes/cleaners 2,700
11,600
Only 50 percent of the expenses for the business meals and out-
of-town meals ($1,600) was deductible under section 274(n), which
reduced the total to $10,000. The 2 percent of adjusted gross
income floor under section 67(a) reduced the resulting $10,000
amount by $1,006 so that the net job expense deduction was
$8,994.
Respondent disallowed the aforesaid deductions in full.
Respondent determined that petitioners did not prove that the
amounts shown were for medical expenses and were paid, and that
they did not establish that the employee business expenses were
paid or incurred or were ordinary and necessary to the taxpayers’
business.
Section 213 provides a deduction for certain medical
expenses. Section 162(a) provides that there shall be allowed as
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