Richard and Judith Haeder - Page 10




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               rental of iron lung or other equipment for therapeutic                 
               use, in or out of hospital; artificial limbs or other                  
               prosthetic appliances; diagnostic laboratory                           
               procedures; drugs and medicine requiring prescriptions;                
               oxygen, anesthesia; blood and plasma, x-ray and radium                 
               treatments; local professional ambulance services;                     
               psychiatric treatment; dental care; surgery and                        
               appliances; eye glasses; hearing aids and examination                  
               thereof; and premiums on accident and health insurance,                
               including hospitalization, surgical and medical                        
               insurance.                                                             
          Petitioner claimed that Mrs. Haeder was eligible to participate             
          in that plan in her capacity as his employee and that he and                
          their minor children were eligible to participate in the plan as            
          Mrs. Haeder’s spouse and dependents.                                        
               During the years at issue, petitioners and their children              
          were covered by an individual health insurance policy issued in             
          petitioner’s name.  The record contains no evidence that, during            
          those years, Mrs. Haeder also had coverage under either a health            
          insurance policy issued in her name or a group health insurance             
          policy.                                                                     
               On the Schedules C for 1989, 1990, 1991, 1992, and 1993,               
          petitioner claimed medical plan expenses of $3,446, $4,197,                 
          $13,140, $4,568, and $8,914, respectively, including medical                
          insurance premiums and medical and dental expenditures for                  
          petitioner, Mrs. Haeder, and their two minor children.  On audit,           
          respondent determined that petitioners substantiated medical plan           
          expenses as follows:                                                        








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