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In 1994, petitioner’s father, Joe Scott (Mr. Scott),
suffered a stroke. Around the same period, Mr. Scott’s wife had
a heart attack and was placed into a nursing home. As a result
of the stroke, Mr. Scott had memory loss and required in-home
care and supervision. Mr. Scott moved in with petitioner.
Petitioner purchased Mr. Scott’s medication and eventually placed
Mr. Scott in a full-care facility.
Petitioner’s brother, James Ivey (Mr. Ivey), moved from New
York to Florida, as Mr. Ivey had financial problems. Mr. Ivey
resided in an apartment paid for by petitioner, and petitioner
paid for some of Mr. Ivey’s food.
During the period at issue, petitioner purportedly owned and
managed residential properties. The four properties were (1) a
house at 409 Washington Avenue, Lake Wales, Florida (Washington);
(2) a condominium at 3440 Park Place, Tampa, Florida (Park
Place); (3) a house at 83 Douglas Way, Frostproof, Florida
(Douglas Way); and (4) an unknown structure at 62 Marshall Lane,
Frostproof, Florida (Marshall Lane).
On her 1996 Federal income tax return, petitioner claimed a
dependency exemption deduction for Mr. Scott and deducted
$18,0052 of medical expenses related to Mr. Scott. On her 1997
2 Petitioner deducted $19,337 less $1,332 (7.5 percent of
adjusted gross income). Sec. 213(a).
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Last modified: May 25, 2011