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$16, and a Schedule C business loss of $32,018. On January 13,
2006, respondent issued to petitioner a notice of deficiency for
2003.
Discussion
Schedule A Medical Expenses
Expenses paid during the taxable year, not compensated for
by insurance or otherwise, for medical care of the taxpayer, her
spouse, or a dependent shall be allowed as a deduction to the
extent that such expenses exceed 7.5 percent of adjusted gross
income. Sec. 213(a). The term “medical care” includes amounts
paid for insurance covering medical care. Sec. 213(d)(1)(D).
On her 2003 return, petitioner claimed itemized deductions
for medical expenses. Petitioner failed to substantiate the
$6,966.21 in medical expenses that remain in dispute. In an
attempt to substantiate the disputed medical expenses, petitioner
produced evidence of payments made to National Finance Center.
The purpose of these payments is not clear. Copies of several of
the canceled checks and cashier’s checks that document these
payments contain writing that was scratched out. Petitioner
testified that the scratched out writing was her Social Security
number. However, the writing that was scratched out on the
cashier’s checks visibly indicates the checks were made out for
Jon Tomlinson, who is petitioner’s brother. Jon Tomlinson was
not petitioner’s dependent for tax purposes. Respondent’s
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