Delbert L. and Margaret J. Baker - Page 36

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          residence at a retirement home under a lifetime care contract was           
          deductible by the individuals as an expense for medical care                
          under section 213, subject to the limitations of the statute.  In           
          the rulings, the taxpayers had entered into agreements with a               
          retirement home under which they became entitled to live in the             
          home and to receive lifetime care that included specified                   
          residential accommodations, meals, and medical care.  In exchange           
          for the promise of the lifetime care, the taxpayers paid a                  
          monthly fee to the homes.                                                   
               In Rev. Rul. 67-185, supra at 70, the taxpayers proved that            
          on the basis of the retirement home’s experience, a portion of              
          the monthly fee was for costs of providing medical care,                    
          medicine, and hospitalization.  The ruling cited the holding in             
          Rev. Rul. 54-457, 1954-2 C.B. 100, that where a university                  
          charges a student a lump-sum fee which includes his education,              
          board, medical care, etc., the portion of the charge which was              
          allocable to medical care is considered a proper medical expenses           
          deduction if there is a breakdown showing the amount of the fee             
          allocable to medical care, or such information was readily                  
          available to the university.  Id. at 71.  Rev. Rul. 67-185,                 
          supra, then stated that the principle in Rev. Rev. 54-457, supra,           
          relating to allocation of the fee, was equally applicable to its            
          situation.  Rev. Rul. 67-185, supra at 71, concluded:                       








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