- 15 -
Under the “plan”, petitioner agreed that Aspiring Artists would
pay up to the $500 deductible for Jennifer’s medical expenses not
covered by her father’s insurance policy. Petitioner signed the
handwritten document creating the “medical plan” agreement dated
August 1, 1996. There were, however, outstanding medical
expenses from March or earlier of 1996. From the record it
appears as though these expenses stem from a period of time prior
to their daughter's commencing her education at VSA. All the
payments made with respect to Jennifer’s medical expenses were
made by personal checks, most of them on checks drawn by Ms.
Pickering. This Court finds that Jennifer’s medical expenses are
not deductible on Schedule C as business expenses, but
petitioners may claim them on Schedule A, Itemized Deductions,
subject to the 7.5-percent limitation of section 213(a).
Validity of the Notice of Deficiency
Petitioners contend that the notice of deficiency issued by
respondent is invalid because it specified July 4, 2000, a legal
holiday, as the last day on which petitioners could file a
petition with the Tax Court. The notice of deficiency states
that if petitioners want “to contest this determination in court
before making any payment, you have 90 days from the date of this
letter * * * to file a petition with the United States Tax Court
for a redetermination of the deficiency.” Petitioners urge this
Court to hold that identifying a legal holiday as the last
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011