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the medical care of the taxpayer, the taxpayer’s spouse, or a
dependent to the extent that such expenses exceed 7.5 percent of
adjusted gross income. In this case, petitioner claimed an
itemized deduction for unreimbursed medical and dental expenses
of $8,805.87 on his 2001 return and attached documentation to his
return purporting to substantiate the expenses. When respondent
issued his notice of deficiency, he did not disallow these
expenses, although he did make a computational adjustment to the
amount of the deduction because of adjustments affecting the
calculation of petitioner’s adjusted gross income. However,
after respondent discovered that some of the documentation
attached to petitioner’s 2001 return may have been falsified,
respondent disallowed all of petitioner’s Schedule A expenses,
including his medical and dental expenses, for failure to
substantiate, and he moved to increase the deficiency to reflect
the disallowance.
At trial, respondent convincingly proved that the
documentation attached to petitioner’s 2001 return to document
his medical and dental expenses had been falsified.
Consequently, the record contains no credible evidence
substantiating petitioner’s medical and dental expenses for 2001,
and we sustain respondent’s determination.
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