- 8 -
Commissioner, supra at 412.]
The expenditures for the educational services will be deductible.
Greisdorf v. Commissioner, 54 T.C. 1684 (1970). If a school or
institution does not qualify as a “special school”, the costs of
medical services rendered are nevertheless deductible. Fay v.
Commissioner, supra; sec. 1.213-1(e)(1)(v)(b), Income Tax Regs.
Section 262 prohibits deductions for personal, living, or
family expenses.
a. Attendant care provider expense
Mr. Emanuel was injured in 1989 while employed by Eastern
Airlines and at the time of the trial was still unable to work.
Because of the injuries, Mr. Emanuel was awarded worker’s
compensation benefits. Mr. Emanuel is unable to walk a distance
greater than a hundred feet or to stand for more than a few
minutes consecutively and relies on a scooter for mobility. He
has also been unable to fully care for himself and has relied on
the assistance of Mrs. Emanuel to help him shower, dress, eat,
and exercise. In 1993, the Worker’s Compensation Court in Miami,
Florida, determined that Mr. Emanuel was to receive the
additional benefit of attendant care services and selected Mrs.
Emanuel as his attendant care provider.
Mrs. Emanuel was paid minimum wage for 10 hours of services
provided to Mr. Emanuel each day. The following amounts were
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