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We are not satisfied that there was no significant element
of personal pleasure, recreation, or vacation in their trips to
Walt Disney World and Universal Studios Florida. Sec. 213(d)(2).
Moreover, petitioners have not substantiated the claimed travel
expenses. Sec. 1.213-1(h), Income Tax Regs. We conclude that
petitioners are not entitled to deduct the travel expenses for
the attendant care provider as a medical expense.
e. Backup generator
Christopher would scratch and bite himself in great distress
when the radio, television, and air conditioning in the home
could not operate due to a loss of power. Power outages would
occur in petitioners’ home three or four times a year.
Petitioners purchased a backup electrical generator for $840 in
1998 to avoid the distress to Christopher when the radio,
television, and air condition were not operating. The generator
was not used to provide electricity to medical equipment for
Christopher.
The electrical generator is a capital expenditure. Secs.
263, 213(d)(1)(A); sec. 1.213-1(e)(1)(iii), Income Tax Regs.
Petitioners’ explanation for the electrical generator is that
they purchased it to ease Christopher’s distress, but this does
not indicate a medical exigency. See Haines v. Commissioner, 71
T.C. 644 (1979). Although the electrical generator may have been
beneficial to Christopher because it operated the radio,
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