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effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure.
Respondent determined deficiencies in petitioners’ Federal
income taxes of $1,648 and $1,159 for the taxable years 1995 and
1996.
The sole issue for decision is whether certain medical
expenses are deductible under section 162(a).1
Some of the facts have been stipulated and are so found.
The stipulations of fact and the attached exhibits are
incorporated herein by this reference. Petitioners resided in
Medford, Wisconsin, on the date the petition was filed in this
case.
Among several other endeavors, petitioners owned and
operated a Christmas tree farm during 1995 and 1996. The
property on which the trees were grown was titled in both
petitioners’ names and is subject to a mortgage for which both
are responsible. At the time of trial, there were approximately
55,000 trees on an 80-acre portion of the farm and petitioners
sold Christmas trees on 14 lots. However, during the years in
issue the farm was in an earlier stage of development and
petitioners were not yet cutting and selling trees. At that
1Respondent’s adjustments for each year to the earned income
credit and the self-employment income tax deduction, as well as
his calculation of petitioners’ liability for self-employment
income tax, are computational and will be resolved by the Court’s
holding on the issue in this case.
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Last modified: May 25, 2011