W. Bradford Davis and Tedde M. Rinker - Page 34

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          10/25  Car rental San Francisco American Osteopathic  103.97                
          Association                                                                 
          convention                                                                  
          11/17  Hotel      San Francisco American Osteopathic  109.00                
          Association                                                                 
          Total                    $836.29                                            
          We therefore allow a deduction for $836.29.                                 
          III.  Schedule A Deductions                                                 
               A.  Personal Medical Expenditures                                      
               On their 1999 tax return, petitioners claimed medical and              
          dental expenditures of $18,659, of which $11,693 was allegedly              
          deductible.7  Respondent denied the deduction.                              
               At trial, petitioners offered another Quicken report which             
          purported to contain their medical expenses for 1999.  The report           
          showed several payments from petitioners’ bank accounts, the                
          amounts of the payments, the payees, and some details about the             
          payments and their purposes.  Dr. Rinker testified that while she           
          and Mr. Davis had medical insurance for their family in 1999                
          through Mr. Davis’s employers, the report included only those               
          medical expenses which were not reimbursed through their medical            
          insurance policy.  Many of the entries on the Quicken report                
          contain notes such as “not covered”, “co pay”, or “copayment”.              
               Section 213(a) generally allows a deduction for expenses paid          
          during a taxable year, not compensated for by insurance or                  


               7  As discussed below, sec. 213 allows a deduction for                 
          medical or dental expenses to the extent that they exceed 7.5               
          percent of adjusted gross income.                                           





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