Paul E. and Jane Anne Gladden Emerson - Page 5




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          Pharmacy in the amount of $1,255.13.  Petitioner testified that             
          these expenses were for prescriptions.  He admitted that it was             
          possible that some of these amounts were for items other than               
          prescriptions.                                                              
               Petitioner presented canceled checks made out to Golden Rule           
          Insurance in the amount of $5,473.37 and Liberty Fund Inc. in the           
          amount of $40.50  The checks made out to Golden Rule Insurance              
          were paid quarterly.  Petitioner testified that they were for               
          health insurance.  Petitioner was not sure whether Liberty Fund             
          Inc. was for health insurance.  Petitioner also presented checks            
          in the amount of $343 made out to doctors and medical                       
          laboratories.                                                               
               It is clear that petitioners incurred medical expenses.                
          Under the Cohan doctrine, we estimate the allowable amounts of              
          expenses as follows.  We allow $880 for prescription expenses,              
          all of the insurance payments to Golden Rule Insurance of                   
          $5,473.37, and all of the doctor and medical laboratory expenses            
          of $343, for a total of $6,696.37, which is more than the $6,393            
          petitioners claimed on their return.  This deduction is subject             
          to a floor of 7.5 percent of adjusted gross income.                         
               Respondent disallowed $3,165 of interest expense.  A                   
          deduction for interest paid on indebtedness during the year is              
          generally allowed under section 163(a).  However, section                   
          163(h)(1) provides that no deduction is allowed for personal                
          interest.  "Personal interest" does not include any "qualified              






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