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Item 1989 1990 1991 1992 1993
Insurance premiums $2,657 $3,211 $4,018 $3,520 $3,936
Out-of-pocket costs 146 986 6,369 1,048 3,834
Total 2,803 4,197 10,387 4,568 7,770
In the notice of deficiency, respondent determined that, although
petitioners had substantiated medical plan expense payments as
summarized above, petitioners were not entitled to deduct any of
the amounts petitioner claimed on the Schedules C for medical
plan expenses. Respondent determined, however, that petitioners
were entitled to deduct substantiated medical expenses on their
Schedules A, Itemized Deductions, subject to the statutory
limitations. At trial, petitioner submitted medical and dental
statements that showed payments for dental expenses totaling
$136, $86, $5,529, and $338 for 1989, 1990, 1991, and 1992,
respectively. It is not clear from the record whether those
payments were included in the amounts previously submitted to the
IRS auditor during the audit of the returns for those years.
Legal and Professional Expenses
On the Schedules C for 1989, 1990, and 1991, petitioner
claimed legal and professional expenses of $175,5 $8,623, and
$4,305, respectively. Petitioner claimed no deductions for legal
and professional expenses on the Schedules C for 1992 and 1993.
5Respondent made no adjustment relating to the legal and
professional expenses claimed for 1989.
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