T.C. Memo. 2006-8
UNITED STATES TAX COURT
DESTA TAYE-CHANNELL AND BRUCE C. CHANNELL, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4166-04. Filed January 18, 2006.
The Telecommunication Relay Service (TRS) enables a
hearing-impaired individual to communicate with a hearing
individual over the telephone through the use of a relay
operator. Ps subscribed to the AdaCom program which
provided an alternative to the TRS through the use of a
computer rather than a relay operator. On their 2000
Federal income tax return, Ps claimed a disabled access
credit. See sec. 44, I.R.C. Ps also claimed a sec. 162,
I.R.C., trade or business expense deduction. R disallowed
the credit and deduction.
Held: Because the AdaCom program was not acquired by
Ps in order for them to comply with the applicable
requirements of the Americans with Disabilities Act of 1990,
Pub. L. 101-336, 104 Stat. 327, the AdaCom program is not an
“eligible access expenditure” for purposes of sec. 44(c),
I.R.C. Svoboda v. Commissioner, T.C. Memo. 2006-1.
Held, further: Ps are not entitled to deduct the cost
of the AdaCom program as a trade or business expense
pursuant to sec. 162, I.R.C., as they did not use the AdaCom
program in a trade or business.
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