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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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