Robert and Martha Emanuel - Page 18




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          some situations, the Court may estimate the amount of medical               
          expenses and allow a deduction to that extent, notwithstanding              
          substantiating documentary evidence in the record.  Cohan v.                
          Commissioner, 39 F.2d 540, 543-544 (2d Cir. 1930); Meyers v.                
          Commissioner, T.C. Memo. 1996-219.  The Court is satisfied that             
          petitioners incurred $1,200 in pool maintenance expenses for each           
          of the years at issue, and petitioners are entitled to deduct the           
          expenses for 1996, 1997, and 1998 as medical expenses to the                
          extent allowable under section 213(a).                                      
               g.   YMCA day camp                                                     
               Christopher was enrolled in a YMCA program during the tax              
          years at issue the cost of which petitioners allege they are                
          entitled to deduct for each of the years at issue as dependent              
          medical expenses.  The brochure for the YMCA program reflects               
          that it is structured to enhance physical and social growth in              
          the areas of recreation and leisure activities for special                  
          populations.                                                                
               The YMCA program was designed to assist a student like                 
          Christopher with severe physical and mental disabilities with               
          physical growth and to treat his problems.  Christopher’s                   
          participation in the program was prompted by his mental and                 
          physical disabilities, and the program had principally a                    
          therapeutic value for him.  See Greisdorf v. Commissioner, 54               
          T.C. 1684, 1690 (1970).  We conclude that the YMCA program was              






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