Legal Opinion

Randolph v. Commissioner

United States Tax Court

Decided December 16, 1976No. Docket No. 2964-74PublishedCited by 21 opinions

Petitioners are allergic to a variety of chemical compounds found in pesticides and herbicides. To avoid severe allergic reactions, petitioners must restrict their diets to chemically uncontaminated foods purchased from health food stores. Chemically uncontaminated food requires special care in growing, packaging, and transporting that results in a retail cost substantially higher than chemically treated food found in ordinary grocery stores.

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Petitioners are allergic to a variety of chemical compounds found in pesticides and herbicides. To avoid severe allergic reactions, petitioners must restrict their diets to chemically uncontaminated foods purchased from health food stores. Chemically uncontaminated food requires special care in growing, packaging, and transporting that results in a retail cost substantially higher than chemically treated food found in ordinary grocery stores. Held, based upon the facts and record in this case, petitioners may deduct as a medical expense the additional cost of chemically uncontaminated foods.

1Opinion of the Court

Wiles, Judge:

Respondent determined a deficiency of $1,480 in petitioners’ income taxes for 1971. The only issue to be decided is whether petitioners may deduct as a medical expense the amount by which the cost of specially grown, packaged, and prepared foods exceeds the cost of ordinary foods.

FINDINGS OF FACT

Some of the facts have been stipulated and are found accordingly.

Petitioners Theron G. and Janet M. Randolph, husband and wife, resided in Chicago, Ill., during 1971, and at the time they filed a petition with this Court. They timely filed a joint return for 1971 with the Internal Revenue…

2Cases cited5 opinions

  1. Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
  2. Havey v. CommissionerUnited States Tax Court · 1949
  3. Cohn v. CommissionerUnited States Tax Court · 1962
  4. Harris v. CommissionerUnited States Tax Court · 1966
  5. Clark v. CommissionerUnited States Tax Court · 1957

3Cited by21 opinions

  1. Moss v. CommissionerUnited States Tax Court · 1983
  2. Kilpatrick v. CommissionerUnited States Tax Court · 1977
  3. Mattes v. CommissionerUnited States Tax Court · 1981
  4. Neil v. CommissionerUnited States Tax Court · 1982
  5. Becher v. CommissionerUnited States Tax Court · 1987

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