Raymond F. Borgmann v. Commissioner of Internal Revenue

For the taxable year 1964, Borgmann sought to deduct a large part of the salary paid, as well as a portion of the cost of room and board furnished, to an employee residing in his home. The deduction was claimed as a medical expense under Sections 213(a) and 213(e) (1) of the Internal Revenue Code of 1954, 26 U.S.C. §§ 213(a), 213(e) (1) 1 The Commissioner disallowed all of the claimed deduction, and the Tax Court upheld the disallowance. Borgmann v. CIR, unofficially reported at 28 T.C.M. 678 (1969). We affirm.

Borgmann does not challenge the Tax Court’s findings of fact. Borgmann, who lived…