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Before applying the 7.5-percent AGI limitation, Mr. Buah
reported $14,520 of medical and dental expenses in 2002.
Respondent allowed $3,982 of that amount and disallowed the
remainder. Copies of medical bills and related documents
indicate that the value of medical services received in 2002
greatly exceeded $3,982. However, Mr. Buah acknowledges that
insurance paid a portion of the medical expenses. For example,
one document indicates that insurance paid $2,242 of the cost of
medical services performed in June 2002 while Mr. Buah was
responsible only for the remaining $502. Mr. Buah has not
demonstrated that the expenses not compensated for by insurance
exceed the amount that respondent allowed. Accordingly,
respondent’s determination on this issue is sustained.5
B. Contributions
In general, section 170(a) allows as a deduction any
charitable contribution made within the taxable year. Mr. Buah
claimed a deduction for cash and noncash contributions of $5,100
in 2002 and $4,665 in 2003. Respondent disallowed $3,618 for
2002 and $2,100 for 2003. The only corroborating evidence that
Mr. Buah introduced are statements from Love International Church
indicating he made contributions of $544 in 2002 and $1,565 in
5 Since we have sustained respondent’s determination on
this issue, we need not address whether Mr. Buah can claim
deductions for medical expenses of his wife and children given
that petitioners filed separate returns and Mrs. Buah claimed the
children as dependents.
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Last modified: November 10, 2007