Stephen T. Fan and Landa C. Fan - Page 5

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          pencils, and notepads had to be disinfected or disposed of due to           
          health requirements.  Petitioner also found use of the VCR and              
          television to be inconvenient because the equipment had to be               
          brought into and removed from the examination room during the               
               Prior to purchasing the system, petitioner did not refuse              
          treatment to a prospective patient because the patient had a                
          hearing impairment.  He did not purchase the system at the                  
          suggestion or recommendation of one of his hearing-impaired                 
          patients, and during the years in issue he did not limit the use            
          of the system to his hearing-impaired patients.  Nevertheless,              
          when compared to handwritten notes, he considers the system to be           
          a more effective and efficient way to communicate with his                  
          hearing-impaired patients.  When used in the examination of a               
          hearing-impaired patient, the system, in some instances, reduced            
          the need for petitioner to communicate with the patient by                  
          handwritten notes.  Petitioner further found that if he used the            
          system during the examination of a hearing-impaired patient, the            
          patient was more likely to understand and agree to any                      
          recommended treatment.  According to promotional materials,                 
          “studies show case acceptance increases by approximately 30                 
          percent with an intraoral camera system.”                                   
               Petitioners filed a timely 1995 Federal income tax return.             
          On a Form 8826, Disabled Access Credit, included with that                  

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