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expenses. Therefore, we hold that petitioner has substantiated
payment of the above listed medical expenses, except for the For
Eyes--Optical expense, in taxable year 1999 in the amount of
$4,197,3 which amount is in addition to the amount respondent
conceded of $18,904.
The rest of petitioner’s claimed medical expenses were
reflected by various documents in Exhibit 7-J. However, while
these documents provided the name and address of each person to
whom payment was due and the amount due for such payment, these
documents did not substantiate that petitioner made the required
payment or that such payment was made in the taxable year 1999.
Petitioner did not introduce into evidence any further
documentation which would substantiate the date of such payment
or if payment of such expenses was actually made. Therefore, we
hold that no further medical expenses have been substantiated by
petitioner.
2. Additions to Tax
a. Section 6651
Respondent determined that petitioner is liable for
additions to tax for: (1) Failure to file a timely return for
taxable year 1999 pursuant to section 6651(a)(1); and (2) failure
to make timely payment of tax pursuant to section 6651(a)(2).
3Monetary amount is rounded to the nearest dollar.
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