RAYMOND V. GERARD
37 T.C. 826 (1962)
NATURE OF THE CASE: This was a dispute over the deductibility of central air
conditioning. Raymond (D) sought review of a determination of a deficiency based upon the
disallowance of a medical expense deduction for the cost of installing a central
air-conditioning unit in P's home.
FACTS: Gerard (P) had a daughter that had cystic fibrosis. She needed special diets,
medicine and a special living environment. She was treated with antibiotics and slept in a
tent that dispensed them into the air. Because of her illness it was dangerous for her to be
exposed to dry, dusty air. To help, P installed air conditioning in one room but that
restricted the child to that room only during the day. Doctors advised that central air
would improve her quality of life. P then installed central air at a cost of $1,300. The
cost increased the value of the home by $800. The IRS disallowed the deduction.
ISSUE:
RULE OF LAW:
HOLDING AND DECISION:
LEGAL ANALYSIS:
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