117 T.C. No. 3
UNITED STATES TAX COURT
STEPHEN T. FAN AND LANDA C. FAN, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 17036-99. Filed July 24, 2001.
In 1995, P purchased an intraoral camera system
(the system) for use in his dental practice. The
system has general applicability and usefulness to all
dental patients. It reduces the time necessary for a
dentist to explain diagnoses, “procedures”, and
recommended treatment with patients. P considered the
system to be a more effective and efficient way to
communicate with hearing-impaired patients. On their
1995 Federal income tax return, Ps claimed a disabled
access credit for the cost of the system. See sec. 44,
I.R.C. R determined that the system was not an
“eligible access expenditure” for purposes of sec.
44(c), I.R.C., and disallowed the credit.
Held: Because the system was not acquired by
petitioner in order for him to comply with the
applicable requirements of the ADA, the system is not
an “eligible access expenditure” for purposes of sec.
44(c), I.R.C.
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