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COONEY v. COMMISSIONER

Docket No. 2656-69.

30 T.C.M. 845 (1971)

T.C. Memo. 1971-201

Daniel T. Cooney and Eleanor M. Cooney v. Commissioner.

United States Tax Court.

Filed August 16, 1971.

Attorney(s) appearing for the Case

Emil Sebetic, 233 Broadway, New York, N. Y., for the petitioners. John D. Shuff, for the respondent.

Memorandum Findings of Fact and Opinion

QUEALY, Judge:

Respondent determined a deficiency of $1,741.68 in petitioners' Federal income taxes for the year 1967. The sole issue before us is whether payment of $12,3221 to Liberty Mutual Insurance Company, pursuant to the settlement of a tort action by the petitioners against certain other parties, was allowable as a medical expense deduction under section 213.2...

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