Juan G. Ibarra and Margarita Ibarra - Page 8

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          parties, was approximately $645.  The Court is satisfied, on this           
          record, that petitioners are entitled to an additional deduction            
          of $645 in medical and dental expenses for 2000.                            
               With respect to all the other itemized deductions and the              
          Schedule C trade or business expenses, petitioners produced no              
          documentary evidence to establish entitlement to deductions in              
          excess of the amounts allowed by respondent in the notice of                
          deficiency, nor is the Court persuaded that they are entitled to            
          deductions in excess of those allowed by respondent.                        
          Accordingly, except for the additional amount allowed for medical           
          and dental expenses, respondent's determinations are sustained.             
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   


                                                  Decision will be entered            
                                             for respondent.3                         






               3    Although the Court allows petitioners an additional               
          $645 itemized deduction for medical expenses, raising their total           
          medical expenses to $1,940, the allowance of $645 will not result           
          in a tax benefit to petitioners because the Court's holding on              
          petitioners' Schedule C, Profit or Loss From Business, activity             
          will increase petitioners' adjusted gross income, thereby                   
          increasing the 7.5 percent threshold of sec. 213(a).                        
          Petitioners' $1,940 in medical expenses will be less than the 7.5           
          percent floor.                                                              





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