James Albert and Beverly Alderman - Page 3

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               Respondent determined a Federal income tax deficiency for              
          petitioners’ 2000 taxable year in the amount of $1,642.  After              
          concessions, the issue for decision is whether petitioners are              
          entitled to deduct a portion of their transportation costs as a             
          medical expense under section 213.                                          
                                     Background                                       
               Some of the facts have been stipulated and are so found.               
          The stipulations of the parties, with accompanying exhibits, are            
          incorporated herein by this reference.  During the year 2000 and            
          through the time the petition was filed in this case, petitioners           
          resided in Excel, Alabama.                                                  
               Petitioner James Albert Alderman (Mr. Alderman) was employed           
          during 2000 as a mathematics teacher at Escambia County Middle              
          School.  Escambia County Middle School is located in Atmore,                
          Alabama.  Petitioner Beverly Alderman (Mrs. Alderman) was                   
          employed in 2000 as a nurse at the Motorola Medical Clinic in               
          Monroeville, Alabama.                                                       
               Mr. Alderman is sight disabled and does not drive.  Due to             
          this disability, Mrs. Alderman drove Mr. Alderman both to and               
          from his job each workday.  Atmore is located to the south of               
          Excel, and the distance from petitioners’ residence to Mr.                  
          Alderman’s place of work was approximately 40 to 45 miles.                  
          Monroeville is located to the north of Excel, and the distance              
          from petitioners’ residence to the clinic where Mrs. Alderman               






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