- 22 - Respondent has negated all nontaxable sources of income alleged by petitioners. Respondent has shown that petitioners did not receive any gifts or inheritances. Most importantly, respondent has negated petitioners’ cash hoard argument. During 1991 and 1992, Mr. Black paid medical insurance premiums of $6,307 and $4,744, respectively. Respondent’s net worth calculation treats such amounts as nondeductible expenditures. However, respondent allowed deductions for 25- percent of the premiums paid as self-employment health insurance. See sec. 162(l)(1). Under section 213(a), personal medical and dental expenses are deductible only to the extent they exceed 7.5 percent of adjusted gross income (AGI). Accordingly, petitioners are not entitled to deduct the remaining 75 percent of the medical insurance premiums paid as personal medical expenses as they do not exceed 7.5 percent of petitioners’ adjusted gross income. Secs. 213(a), 162(l)(3)(A). Petitioners have not proven that any deduction above the 25 percent allowed is appropriate. Petitioners appear to argue that some portion of the medical insurance premiums should be deductible under section 162(a) as ordinary and necessary business expenses. The parties have stipulated that Mr. Black had a health insurance policy covering himself and his family as well as several employees. However, the record is silent as to what portion of the premiums paid wasPage: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: March 27, 2008