Lisa J. Tomlinson - Page 5




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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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