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as previously noted, was diagnosed with Parkinson’s disease in
approximately 1980. However, petitioners have provided no
substantiation that such expenses were incurred. At trial,
petitioner did not testify as to any medical expenses that were
incurred during taxable year 1999. Petitioner did not submit any
evidence either before, during, or after trial that would prove
any medical expenses were incurred during taxable year 1999.
Upon the basis of the record and because petitioners have
failed to provide any substantiation to support their claimed
deduction for medical and dental expenses, we find that we cannot
estimate any amounts of petitioners’ deduction under the Cohan
rule, and we sustain respondent’s disallowance of petitioners’
claimed deduction for medical and dental expenses in the amount
of $21,358. Sec. 6001; sec. 1.6001-1(a), (e), Income Tax Regs.
2. Real Estate Taxes
Petitioners claimed a Schedule A deduction for real estate
taxes paid during taxable year 1999 of $3,456 on their Federal
income tax return. Respondent agrees that petitioners are
entitled to deduct, under section 164, $1,017 of the claimed
Schedule A deduction for real estate taxes. However, respondent
contends that petitioners are not entitled to the additional
$2,439. Respondent determined that petitioners did not prove
that the claimed real estate taxes were incurred or, if incurred,
that they were paid during taxable year 1999.
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