Lepson v. Commissioner

1982 T.C. Memo. 304, 44 T.C.M. 19, 1982 Tax Ct. Memo LEXIS 444
CourtUnited States Tax Court
DecidedJune 2, 1982
DocketDocket No. 13949-80.
StatusUnpublished

This text of 1982 T.C. Memo. 304 (Lepson v. Commissioner) is published on Counsel Stack Legal Research, covering United States Tax Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Lepson v. Commissioner, 1982 T.C. Memo. 304, 44 T.C.M. 19, 1982 Tax Ct. Memo LEXIS 444 (tax 1982).

Opinion

CHARLES R. LEPSON AND LINDA A. LEPSON, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Lepson v. Commissioner
Docket No. 13949-80.
United States Tax Court
T.C. Memo 1982-304; 1982 Tax Ct. Memo LEXIS 444; 44 T.C.M. (CCH) 19; T.C.M. (RIA) 82304;
June 2, 1982.

*444 Held, amounts paid for the purchase of a tractor and snow blower were not deductible as medical expenses. Held further, the Court will not consider an issue not raised in the pleadings.

Ralph W. Levinson, for the petitioners.
Sandra M. Gilmore, for the respondent.

WHITAKER

MEMORANDUM FINDINGS OF FACT AND OPINION

WHITAKER, Judge:* Respondent determined a*445 deficiency in petitioners' Federal income tax for 1977 in the amount of $ 701. Due to concessions, the only remaining issues are (1) whether the sum of $ 2,945, which is the amount paid by petitioners for a tractor with a leaf sweeper and snow blower, exclusive of sales tax, was properly claimed by petitioners as a medical expense deduction under section 213(a), 1 and (2) whether amounts paid to the Jewish Community Center were deductible as charitable contributions.

Medical Expense Deduction

The driveway leading to the garage of petitioners' residence, in Rochester, N.Y., is approximately 290 feet long by 7 feet wide. It is covered by gravel and has a ridge running along the center. It is extremely difficult to clear snow from the driveway by using only a shovel, a snowplow, or a hand-held snow blower.

Both petitioners have received medical treatment for back*446 problems from time to time. Early in December 1977, petitioners' physician recommended that both Mr. and Mrs. Lepson avoid shoveling snow, raking, and any other heavy or unusual activity that would put a strain on their backs. The doctor advised them to purchase a riding tractor with a snow blower and leaf sweeper. On December 3, 1977, petitioners purchased an I. H. Cub tractor with a snow blower and a leaf sweeper. On their joing 1977 income tax return, petitioners designated the tractor as a "medical apparatus" and deducted $ 2,945, the purchase price exclusive of tax, as a medical expense. On audit, respondent disallowed this deduction.

Petitioners claim that the amount paid for the tractor and snow blower was a deductible medical expense under section 213 because use of the tractor and snow blower reduced the chances of their reinjuring their backs. Respondent argues, however, that it was not a medical expense but was a personal, living, or family expense, which is nondeductible under section 262. We agree with respondent.

Section 213(a) allows a deduction for expenses paid for the medical care of the taxpayer, his spouse, and dependents if the expenses are not reimbursed*447 by insurance or otherwise. Expenses for medical care include amounts paid for the mitigation, treatment or prevention of disease. Sec. 213(e)(1). Although section 263 and the regulations thereunder provide that capital expenditures are generally not deductible, a capital expenditure may qualify as a medical expense if its "primary purpose" is medical care. Sec. 1.213-1(e)(1)(iii), Income Tax Regs.

Because section 213 is an exception to the general rule of section 262 that "no deduction shall be allowed for personal, living, or family expenses," it must be interpreted narrowly with respect to expenses that are conventionally understood to be personal, living, or family expenses. Atkinson v. Commissioner,44 T.C. 39, 49 (1965). Thus, expenses will not be considered medical expenses if they are primarily personal living expenses, Stringham v. Commissioner,12 T.C. 580, 584 (1949), affd. per curiam 183 F.2d 579 (6th Cir. 1950), and petitioners must show that the contested expenses bear a proximate relation to the diagnosis, cure, mitigation, treatment, or prevention of disease. Havey v. Commissioner,12 T.C. 409, 412 (1949).*448 Borrowing from tort law, the requirement of proximate relationship has been stated as a "but for" test, requiring the taxpayer to show both that the expenditure was an essential element of the treatment and that it would not have otherwise been incurred for nonmedical reasons. Jacobs v. Commissioner,62 T.C. 813, 819 (1974).

Within these parameters, the determination whether an expenditure is for medical care of for personal living expenses is a question of fact. See

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Raul Llorente v. Commissioner of Internal Revenue
649 F.2d 152 (Second Circuit, 1981)
Havey v. Commissioner
12 T.C. 409 (U.S. Tax Court, 1949)
Stringham v. Commissioner
12 T.C. 580 (U.S. Tax Court, 1949)
Gerber v. Commissioner
32 T.C. 1199 (U.S. Tax Court, 1959)
Atkinson v. Commissioner
44 T.C. 39 (U.S. Tax Court, 1965)
Frentz v. Commissioner
44 T.C. 485 (U.S. Tax Court, 1965)
Jacobs v. Commissioner
62 T.C. No. 87 (U.S. Tax Court, 1974)
Estate of Mandels v. Commissioner
64 T.C. 61 (U.S. Tax Court, 1975)
Markwardt v. Commissioner
64 T.C. 989 (U.S. Tax Court, 1975)
Llorente v. Commissioner
74 T.C. No. 20 (U.S. Tax Court, 1980)

Cite This Page — Counsel Stack

Bluebook (online)
1982 T.C. Memo. 304, 44 T.C.M. 19, 1982 Tax Ct. Memo LEXIS 444, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lepson-v-commissioner-tax-1982.