Ralph E. Frahm & Erika C. Frahm - Page 20




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          and the 2002 Schedule F, respectively.25  A taxpayer, including             

               25With respect to the $10,182 deduction that petitioners               
          claimed for “Employee benefit programs” in the 2000 Schedule F,             
          respondent concedes that petitioners are entitled to deduct                 
          $3,928 of those expenses.  That conceded amount, which has been             
          rounded to the nearest dollar, consists of premiums of $55.46 for           
          Ms. Frahm’s AARP policy, premiums of $548 for Ms. Frahm’s Conseco           
          policy, and all noninsurance medical expenses of $3,325.  The               
          disallowed portion (i.e., $6,254) pertains to the premiums that             
          the parties stipulated were paid for Mr. Frahm’s Wellmark Plan C            
          policy.  See supra note 4.  In the notice, respondent determined            
          that although petitioners are not entitled to deduct in the 2000            
          Schedule F the insurance premiums paid during 2000 for Mr.                  
          Frahm’s Wellmark Plan C policy, petitioners are entitled to                 
          deduct under sec. 162(l) 60 percent of those premiums.                      
               With respect to the $14,948 deduction that petitioners                 
          claimed for “Employee benefit programs” in the 2001 Schedule F,             
          respondent concedes that petitioners are entitled to deduct                 
          $6,200 of those expenses.  That conceded amount, which has been             
          rounded to the nearest dollar, consists of premiums of $548 for             
          Ms. Frahm’s Conseco policy, premiums of $575.96 for Ms. Frahm’s             
          long-term care policy, and all noninsurance medical expenses of             
          $5,076.  The disallowed portion (i.e., $8,748) pertains to the              
          premiums that the parties stipulated were paid for Mr. Frahm’s              
          Wellmark Secure Blue Select policy and Mr. Frahm’s long-term care           
          policy.  See supra note 11.  In the notice, respondent determined           
          that although petitioners are not entitled to deduct in the 2001            
          Schedule F the insurance premiums paid during 2001 for Mr.                  
          Frahm’s Wellmark Secure Blue Select policy and Mr. Frahm’s long-            
          term care policy, petitioners are entitled to deduct under sec.             
          162(l) 60 percent of those premiums.                                        
               With respect to the $13,961 deduction that petitioners                 
          claimed for “Employee benefit programs” in the 2002 Schedule F,             
          respondent concedes that petitioners are entitled to deduct                 
          $3,908 of those expenses.  That conceded amount, which has been             
          rounded to the nearest dollar, consists of premiums of $548 for             
          Ms. Frahm’s Conseco policy, premiums of $575.96 for Ms. Frahm’s             
          long-term care policy, and all noninsurance medical expenses of             
          $2,784.  The disallowed portion (i.e., $10,053) pertains to the             
          premiums paid for Mr. Frahm’s Wellmark Secure Blue Select policy            
          and Mr. Frahm’s long-term care policy.  In the notice, respondent           
          determined that although petitioners are not entitled to deduct             
          in the 2002 Schedule F the insurance premiums paid during 2002              
                                                             (continued...)           






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