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Paying the medical or nursing home expenses of others: easing the financial burden by maximizing the deductions.

The financial burden on taxpayers who pay the medical or nursing home expenses incurred by others may be considerably reduced by careful planning. Some planning parameters are (1) the dependency status of the person who incurred the medical or nursing home expenses; (2) the deductibility of the medical care and nursing home expenses; (3) the timing of the payments; (4) the reimbursement of payments; (5) the taxpayer's adjusted gross income (AGI); and (6) the taxpayer's tax rate. As this article will illustrate, within these parameters, taxpayers may be able to structure their affairs to maximize the tax benefit of deducting the medical and nursing home expenses incurred by others.

Dependency Status

For medical care and nursing home expenses to be deductible, the person for whom the expenses are paid must be an individual taxpayer's dependent either at the time the medical care or nursing home services are rendered or at the time the expenses are paid.(1) Under Sec. 152(a), a "dependent" is any person who for the calendar year in which the taxpayer's tax year begins meets the relationship or member of household, support and citizenship tests.

A common mistake is to assume that the medical expense deduction is lost if the dependency exemption cannot be taken. The Sec. 151 dependency exemption is subject to a gross income test. For purposes of the dependency exemption, an individual is not treated as a dependent if he has gross income equal to (or greater than) the exemption amount ($2,350 for 1993) for the year. However, Sec. 152 does not require a gross income test in order for an individual to be a dependent. Rather, for purposes of determining the deductibility of medical care and nursing home expenses, the definition of "dependent" in Sec. 152 controls. Therefore, an individual may be a dependent for purposes of the deductibility of medical care or nursing home expenses but not for exemption purposes.(2)

* Relationship test

An individual must bear a certain relationship to the taxpayer, by being the taxpayer's (1) child or the child's descendant;(3) (2) stepchild; (3) brother or sister; (4) stepbrother or stepsister; (5) parent, grandparent, great-grandparent, etc.; (6) stepfather or stepmother; (7) aunt, uncle, niece or nephew; (8) son-in-law or daughter-in-law; (9) father-in-law or mother-in-law; or (10) brother-in-law or sister-in-law.(4) (A foster parent does not meet the relationship test, however.) Any of these relationships that are established by marriage are not terminated by death or divorce. For example, a widower who continues to support his father-inlaw after the death of his wife may still claim the father-in-law as a dependent.(5)

If a joint return is filed, the required relationship needs to exist with only one of the spouses, regardless of which spouse actually furnishes the support. For example, a husband and wife filing a joint return may claim the wife's aunt as a dependent even though the husband is the one who furnishes the chief support. If a separate return is filed, the required relationship needs to exist with the taxpayer. An individual related to the spouse but not to the taxpayer cannot qualify as the taxpayer's dependent except as a member of the taxpayer's household. For example, a husband filing a separate return could not claim his wife's aunt unless she met the member of household test.

* Member of household test

An individual must have as his principal place of abode the taxpayer's home and be a member of the taxpayer's household for the entire tax year of the taxpayer,(6) but is not required to be related to the taxpayer.(7) The taxpayer must maintain the household and both the taxpayer and the dependent must occupy it.(8) The taxpayer maintains the household if he pays more than half the household expenses, even if the dependent owns the home.(9)

The taxpayer and the dependent are treated as occupying the household for the entire year notwithstanding temporary absence due to special circumstances, e.g., indefinite confinement in a nursing home for constant medical care.(10) A dependent who dies before the end of the taxpayer's tax year meets the occupancy requirement, provided the dependent lived in the taxpayer's household during the entire part of the year before death.(11)

An individual does not meet the member of household test if the relationship between such individual and the taxpayer is in violation of local law.

* Support test

An individual must receive over half of his support from the taxpayer.(12) The support test is strictly one of cost based on the amount of support for the year, not on when it is provided.(13) For example, if a person supports himself for three-quarters of the year and spends $10,000 and the taxpayer supports him for the remaining quarter of the year and spends $10,001, then the taxpayer meets the support requirement. On the other hand, if one son supports his mother for seven months he still does not meet the support test if another son spends more than he did in the remaining five months.(14)

The term "support" includes payments for, and the fair market value of, property used to provide food, lodging, clothing, education, medical and dental care, recreation, transportation and similar necessities.(15)

When two or more taxpayers contribute to the support of an individual, a taxpayer may be treated as contributing over half of the support of the individual for the calendar year if (1) no one person contributes over half of the individual's support; (2) each member of the group that collectively contributes more than half of the support of the individual would be entitled to claim the individual as a dependent but for the fact that he did not contribute more than one-half of such support; (3) the member of the group claiming the individual as a dependent contributes more than 10% of the individual's support; and (4) each other person in the group who contributes more than 10% of such support files a written declaration that he will not claim the individual as a dependent for any tax year beginning in such year.(16)

Example 1: During the current tax year, brothers A, B, C and D contribute the entire support of their mother in the following percentages: A, 30%; B, 20%; C, 29%; and D, 21%. Any one of the brothers would be entitled to claim his mother as a dependent, except for the fact that none contributes more than half of her support. Consequently, any one of the brothers could claim the mother as a dependent provided a written declaration from each of the other brothers is attached to his income tax return. Even though A and D together contribute more than one-half the support of the mother, A, if he wished to claim his mother as a dependent, would be required to attach written declarations from B, C and D on his income tax return, since each of them contributed more than 10% of the support and, but for the support requirement, they would have been entitled to claim the mother as a dependent.(17)

* Citizenship test

An individual claimed by the taxpayer as a dependent must be a U.S. citizen, a U.S. national (e.g., an American Samoan) or a resident of a country contiguous to the United States.(18)

The Deductibility of Medical Care

and Nursing Home Expenses

Expenses for medical care are deductible if incurred for the "prevention or alleviation of a physical or mental defect or illness."(19) Medical care includes operations or treatments affecting any portion of the body and "the diagnosis, cure, mitigation, treatment, or prevention of disease"(20) (e.g., hospital services, nursing services (including nurses' board paid by the taxpayer), medical, laboratory, surgical, dental and other diagnostic and healing services, X-rays, medicine and drugs, artificial teeth or limbs, and ambulance hire(2l)).

Medical care does not include cosmetic surgery, illegal operations or treatments, or treatments beneficial to general health.(22) Cosmetic surgery (e.g., hair transplants, electrolysis, liposuction) is any procedure directed at improving the patient's appearance that does not meaningfully promote the proper function of the body or prevent or treat illness or disease.(23)

Nursing home expenses are deductible to the extent they are incurred for medical care.(24) The nature of the institution does not determine whether expenses are medical expenses.(25) Personal and living expenses incurred by an individual in a nursing home, such as meals and lodging, are not medical expenses. However, meal and lodging expenses that are incidental to medical care are deductible if the resident is in the nursing home because his condition is such that the availability of medical care in such institution is a principal reason for his presence there and meals and lodging are furnished to him while he requires continual medical care.(26)

For example, in Counts,(27) the taxpayer sought to deduct the expenses of nursing home care for his infirm father, who suffered from high blood pressure and a gall bladder condition. The father was not ambulatory; he required nursing assistance for bathing and took meals in bed. The nursing home itemized charges for medical items such as drugs, injections and dressings, and rendered a lump-sum "maintenance" charge that included the cost of nursing services, food and room fees. Since the maintenance charge was a necessary incident to the medical care, the entire meal and lodging cost was deductible.

In contrast, if an individual is in an institution and his condition is such that the availability of medical care in that institution is not a principal reason for his presence there, only that part of the total expense attributable to medical care is deductible. In such a case, expenses for meals and lodging are not deductible.(28)

For example, in Robinson,(29) there was no evidence that a retirement home resident who entered solely because of failing vision received any medical or nursing care. Since the resident entered in good health, medical care was not the principal reason for his presence in the home. Consequently, no part of the payments to the home was deductible.

Timing of the Payments

The timing of the incurrence of medical and nursing home expenses and their payment determines the year of deductibility. Generally, a deduction is allowable only for medical or nursing home expenses incurred and paid during the tax year regardless of the method of accounting used by the taxpayer in making his income tax return. Medical and nursing home expenses incurred but not paid during the tax year are not deductible.(30) When a cash-basis taxpayer deposits a check in a mailbox before the end of the year, the post office is deemed to be the agent of the recipient.

The deductibility of medical and nursing home expenses is not affected by making payment with borrowed money. For example, a taxpayer who executed a note to a hospital in 1964, then later that year paid off the note with the proceeds of a bank loan paid in 1965, was entitled to a medical deduction in 1964 when he delivered the note to the hospital, not in 1965 when he paid it off. Use of a bank credit card to pay medical expenses is treated as a payment made with borrowed money. Thus, medical or nursing home expenses may be deducted in the year the charge is made and not when the credit card holder pays the credit card issuer.(31)

Prepayments of medical or nursing home expenses are not currently deductible unless there is a contractual obligation to pay in the current year.(32) For example, the portion of the entrance fee to a life-care facility allocable to the resident's medical care when the obligation to pay the facility is incurred at the time of payment is deductible currently despite the fact the medical services will not be performed until a future time, if at all.(33)

Reimbursement of Payments

Medical or nursing home expenses reimbursed by insurance or otherwise are not deductible.(34) The availability of funds in a joint bank account does not constitute reimbursement unless the taxpayer has ownership rights to all the funds in the account. For example, in Jewel,(35) a taxpayer drew checks on his personal account to pay the medical expenses of his parents. These payments amounted to more than half the parents' total support. The taxpayer claimed the medical expenses as deductions on his own return. The IRS barred this deduction because the taxpayer could have been reimbursed from the parents' funds deposited in a three-way joint bank account of the father, mother and son. The Tax Court held it was immaterial that the taxpayer might have been reimbursed. The joint bank account did not give the taxpayer an unrestricted right to either the interest or principal. The IRS itself treated the interest as taxable to the parent who made the deposits. Under then applicable Indiana law, there was no transfer of funds from the parents to the taxpayer by way of the joint account. Therefore, the taxpayer could deduct the medical expenses he paid for both parents.

Other reimbursements include amounts received by a taxpayer from (1) social security and state old age assistance in his capacity as his dependent mother's guardian;(36) (2) his brothers for his mother who was a dependent under a multiple support agreement;(37) and (3) his aunt's pension.(38)

Other reimbursements do not include amounts received as a gift. However, whether specifying that the purpose of the gift is to pay for medical or nursing home expenses constitutes reimbursement is not clear. In Litchfield,(39) the court differentiated between a reimbursement - the situation in the case - and the hypothetical situation in which a father makes a monetary gift to his son to help pay the medical expenses for one of the son's children. In the hypothetical case, the payment is a gift, not a reimbursement. The son actually incurs and pays the expenses. The court did not address whether a gift from the father to the son with specific instructions to use it to pay his grandson's medical bills would constitute reimbursement.

The tax treatment of medical or nursing home expense reimbursements depends on whether they are received in the same tax year in which medical expenses are paid. The total amount of allowable medical or nursing home expenses paid must be reduced by insurance or other reimbursements received during the same tax year. Medical expense reimbursements received in a tax year after that in which a deduction for them was claimed must be included in gross income in that subsequent year to the extent attributable to (and not in excess of) the medical care deduction allowed for any prior tax year.(40) Amounts received as refunds of life-care facility fees when a patient moves out of the facility are covered by the above rules.(41)

The Taxpayer's AGI

An individual taxpayer may deduct expenses incurred for medical care to the extent that such expenses exceed 7.5% of his AGI.(42) Dependents who have reached 65 are subject to the same 7.5% floor as those under 65. A low AGI taxpayer can exceed the 7.5% floor with lower medical expenses than a high AGI taxpayer. The same amount of medical expenses may be above the 7.5% floor for a low AGI taxpayer but below the 7.5% floor for a high AGI taxpayer. In this case, the same amount of medical or nursing home expenses is deductible for a low, but not a high, income taxpayer.

Example 2: Taxpayer B filed a joint return for calendar year 1991 and reported an AGI of $30,000. B may deduct only those medical or nursing home expenses in excess of $2,250 (7.5% x $30,000). During 1991, B paid medical expenses of $4,400 incurred by his dependents. Therefore, B may deduct $2,150 ($4,400 - $2,250). Taxpayer C filed a joint return for calendar year 1991 and reported an AGI of $60,000. C may deduct only those expenses in excess of $4,500 (7.5% x $60,000). During 1991, C paid medical expenses of $4,400 incurred by his dependents. This amount is the same as the amount paid by B, but C receives no deduction because he has not exceeded his 7.5% floor of $4,500.

The Taxpayer's Tax Rate

When the deductible amount of medical expenses is large, the high AGI taxpayer realizes a greater tax savings than the low AGI taxpayer for the same amount of medical expenses. This result is caused by the interaction of the graduated tax rate system and the amount of the medical deduction. For a taxpayer with a 28% marginal tax rate, taxes are reduced by $28 for each $100 of medical expense deductions above the 7.5% floor. For a taxpayer with a 15% marginal tax rate, taxes are reduced by only $15 for each $100 of medical expense deductions above the 7.5% floor.

Example 3: Taxpayer X filed a joint return for calendar year 1991 and reported an AGI of $30,000. X's marginal tax rate is 15%. X may deduct only those medical or nursing home expenses in excess of $2,250 (7.5% x $30,000). During 1991, X paid medical expenses of $8,800 incurred by his dependents. Therefore, X may deduct $6,550 ($8,800 - $2,250). Since X is in the 15% bracket, this deduction will save him $982.50 in taxes ($6,550 x 15%). Taxpayer Y filed a joint return for calendar year 1991 and reported an AGI of $60,000. Y's marginal tax rate is 28%. Y may deduct only those medical or nursing home expenses in excess of $4,500 (7.5% x $60,000). During 1991, Y paid medical expenses of $8,800 incurred by his dependents. This amount is the same as the amount paid by X. Y may deduct $4,300 ($8,800 - $4,500). As a 28% bracket taxpayer, Y will save $1,204 in taxes ($4,300 x 28 %). For the same amount of medical or nursing home expenses paid, Y's tax saving is $221.50 greater than X's.

Planning Considerations

The planning objective for taxpayers is to maximize their tax savings from the deduction of the medical or nursing home expenses of their dependents. Generally, this may be achieved by exceeding the 7.5 % floor to as great an extent as possible within the parameters of the Code. A taxpayer may exceed this floor through a variety of strategies. * Timing the incurrence and payment of medical and nursing home expenses. * Selecting the appropriate filing status. * Deciding who among a group supporting an individual should be entitled to claim the individual as a dependent under a multiple support agreement. * Paying directly the dependent's medical care or nursing home expenses. * Shifting the medical or nursing home expense deduction from the dependent to the taxpayer. * Monitoring the health of the dependent in a continuing care retirement community. * Lowering the taxpayer's AGI.

* Timing

Timing the incurrence and payment of the medical or nursing home expenses may enable a taxpayer to exceed the 7.5% floor when otherwise he might not, or to exceed it by a larger amount. The incurrence of medical or nursing home expenses that otherwise may be spread over two or more tax years by the taxpayer and his dependents may be bunched into one tax year. This bunching may be achieved by delaying or accelerating the incurrence of medical or nursing home expenses. For example, the purchase of medicine used in the treatment of chronic ailments may be delayed or accelerated, as may many elective medical procedures (e.g., operations for hernia, temporal mandibular syndrome, stripping of varicose veins, misaligned discs, deviated septum).

Example 4: Taxpayer Y's AGI is $30,000. Y needs an operation that may be delayed or accelerated. The expenses of this operation are deductible. The unreimbursed portion of these expenses is $1,500. Y's dependent parent also needs an operation that may be delayed or accelerated. The expenses for the dependent's operation are also deductible. The unreimbursed portion of the dependent's medical expenses is also $1,500. If these operations are spread over two tax periods, Y will not be able to meet his floor of $2,250 (7.5% x $30,000). However, by bunching both operations into one tax year, Y will be allowed a $750 medical expenses deduction ($3,000 - $2,250).

Similarly, the payment of medical or nursing home expenses that otherwise may be spread over two or more tax years by the taxpayer may be bunched into one tax year. Taxpayers experiencing temporary cash flow problems can bunch their payments for medical or nursing home expenses into the tax year that would provide them with the greatest deduction by borrowing money. To minimize interest expense, taxpayers should borrow and remit payment as close to December 31 as possible.

Example 5: Taxpayer Z's AGI is $20,000. Z and his dependents incur $2,000 in medical expenses. Because Z is experiencing a temporary cash flow problem, he pays $1,000 of these expenses in the year in which they were incurred and the remaining $1,000 in the following year. Consequently, Z has no deduction in either year. However, if the entire $2,000 is paid in the year in which he and his dependents incurred the medical expenses, then the deduction is $500 ($2,000 - (7.5% x $20,000)). Z may obtain this deduction by borrowing the needed $1,000.

* Filing status

A married taxpayer may be able to exceed the 7.5% floor when otherwise he might not, or to exceed it by a larger amount, by filing separately, rather than jointly.

Example 6: Husband H and wife W have an AGI of $20,000 each. H and W pay $4,000 in deductible unreimbursed medical or nursing home expenses for W's aunt in the year in which they were incurred. The deduction on W's separate return would be $2,500 ($4,000 - (7.5% x 20,000)). On a joint return, the deduction would be $1,000 ($4,000 - (7.5% x the combined AGI of $40,000)).

Caution: Because W's aunt does not satisfy the relationship test, H cannot deduct her medical expenses on a separate return unless the aunt is a member of H's household. Furthermore, taxpayers filing separate returns may not take advantage of the deduction for two-earner couples or the child care credit.

* Multiple support agreements

The tax benefit of the medical or nursing home deduction may be significantly different for each member of a group supporting an individual. The previous discussion illustrated how the tax savings from medical and nursing home deductions is a function of the interplay of a taxpayer's AGI and tax rate. Generally, relatively small deductions benefit low AGI taxpayers more than high AGI taxpayers and relatively high deductions benefit high AGI taxpayers more than low AGI taxpayers. However, the previous discussion also implied that only by comparative calculations can it be determined who among a group supporting an individual would realize the greatest tax savings from the deduction for medical or nursing home expenses. From the standpoint of minimizing taxes for the family as a whole, the taxpayer entitled to claim a dependent under a multiple support agreement should be the one who would realize the greatest tax savings from the medical or nursing home expense deductions. Since the amount of the deduction, AGI and tax rate of the members of the group supporting an individual may vary from year to year, the comparative calculations should be made each tax year. The taxpayer entitled to claim a dependent under a multiple support agreement may be changed accordingly.

Reimbursement is a potential pitfall for the taxpayer entitled to claim an individual as a dependent under a multiple support agreement. The taxpayer may lose part of the deduction he would otherwise be allowed for his payment of the dependent's medical or nursing home expenses because of the contributions made by other members of the group supporting the individual. These contributions may be regarded as "compensating" the payor for part of his expenses, e.g., contributions received by a child from siblings for the joint support of a parent. To avoid this potential pitfall, the child who claims the parent as a dependent under a multiple support agreement should pay the parent's medical expenses without reimbursement from the other children. If a parent's support consists of medical expenses plus other outlays for food, clothing, etc., it may be possible for the taxpayer who takes the parent as a dependent to do so by paying all the medical expenses while the other children pay the nondeductible expenses. Alternatively, the siblings may specify that contributions made by them to the taxpayer who pays the parent's medical expenses are made for the nonmedical portion of the support.

* Direct payment

Generally, taxpayers should not give money to their dependents to pay their medical or nursing home expenses. By doing so, the taxpayers may lose all or a portion of the medical expense deduction. Instead, taxpayers should provide their dependents with money only for nonmedical necessities, such as food and clothing. The taxpayers should pay their dependents' medical expenses directly.

* Shifting the deduction

The medical expense deduction may be shifted from the dependent for whom it may be of little value to the taxpayer who may benefit from the deduction. For example, if a dependent parent is not able to use the medical expense deduction, the deduction should be shifted from the parent to the child who claims the parent as a dependent by a gift or loan from the parent to the child.(43) The child may pay the bills personally and take the deduction.

To avoid the issue of whether specifying the purpose of the gift constitutes reimbursement, monetary gifts should not specify the purpose for which the money is to be used.

* Monitoring health

A dependent whose principal reason for entering an institution was not medical care should be monitored for deterioration. Once the dependent's health deteriorates to the point at which his principal reason for being in the institution is medical care, expenses incidental to medical care, such as room and meals charges, become deductible. The change in health status may be documented by reports on the dependent's physical and mental condition, the types of services being provided, statements from the attending physician and admission requirements.

For example, a healthy dependent parent enters a medically equipped and staffed continuing care retirement community that is contractually obligated to provide lifetime care. At the time the parent enters the nursing home, charges for meals and lodging are not deductible by the child who claims the parent as a dependent. If the parent's health later deteriorates to the point at which the availability of medical care becomes a primary reason for his presence at the nursing home, all the retiree's expenses, including charges for meals and lodging, become deductible by the child.

* Lowering AGI

Some taxpayers may be able to lower their AGI by changing the composition of their investment portfolio. Taxpayers with significant dividend income from equity securities or taxable interest income from interest-bearing investments (such as certificates of deposit) may be able to shift their investments into nontaxable interest-bearing instruments. Such a shift may enable them to lower their AGI and thereby realize a greater tax saving from deducting the medical care or nursing home expenses of their dependents.

* Conclusion

Many taxpayers pay unreimbursed medical care or nursing home expenses incurred by their dependents. The most common situation probably is the one in which the dependent is the taxpayer's parent. However, the rules for the deductibility of medical or nursing home expenses apply to all dependents. Many taxpayers can comply with these rules while at the same time maximizing the deduction for the medical or nursing home expenses of their dependents.

(1) Regs. Sec. 1.213-1(e)(3). (2) Regs. Sec. 1.213-1(a)(3)(i). (3) Regs. Sec. 1.151-3(a). (4) Sec. 152(a). (5) Regs. Sec. 1.152-2(d). (6) Sec. 152(a)(9). (7) Regs. Sec. 1.152-1(b). (8) Id. (9) Rev. Rul. 64-41, 1964-1 CB 84. (10) Rev. Rul. 66-28, 1966-1 CB 31. (11) Regs. Sec. 1.152-1(b). (12) Sec. 152(a). (13) Regs. Sec. 1.152-1(a). See also Hazel Newman, 28 TC 550 (1957); William J. Sewell, TC Memo 1973-250. (14) See, e.g., James F. Scott, TC Memo 1950-248; Thomas W. Otis, TC Memo 1957-67. (15) Regs. Sec. 1.152-1(a)(2)(i). See also IRS Publication No. 17, Your Federal Income Tax (1992), at 30. (16) Regs. Sec. 1.152-3(a). (17) Adapted from Regs. Sec. 1. 152-3(b), Example (1). (18) Sec. 152(b)(3); Regs. Sec. 1.152-2(a); Robert H. Hoyle, TC Memo 1970-172; Reza Rezazadeh, 356 F2d 898 (7th Cir. 1966)(17 AFTR2d 416, 66-1 USTC [paragraph] 9274), aff'g TC Memo 1965-78. (19) Regs. Sec. 1.213-1(e)(1)(ii). (20) Sec. 213(d)(1)(A); Regs. Sec. 1.213-1(e)(1)(i). (21) Regs. Sec. 1.213-1 (e)(1)(ii). (22) Id. (23) Sec. 213(d)(9)(B). (24) Rev. Rul. 67-185, 1967-1 CB 70. (25) Regs. Sec. 1.213-1(e)(1)(v). (26) Regs. Sec. 1.213-1(e)(1)(v)(a). (27) W.B. Counts, 42 TC 755 (1964). (28) Regs. Sec. 1.213-1(e)(1)(v)(b). (29) John Robinson, 51 TC 520 (1968). (30) Regs. Sec. 1.213-1(a)(1). (31) Rev. Rul. 78-39, 1978-1 CB 73. (32) Est. of Helen W. Smith, 79 TC 313 (1982); Rev. Ruls. 75-302, 1975-2 CB 86, and 75-303, 1975-2 CB 87; Robert S. Bassett, 26 TC 619 (1956). (33) Rev. Rul. 75-302, id.; Smith, id.; IRS Letter Ruling 8213102 (12/30/81). (34) Sec. 213(a); Regs. Sec. 1.213-1(a)(3)(i). (35) William C. Jewell, 69 TC 791 (1978). (36) Robert W. Hodge, 44 TC 186 (1965). (37) Loring P. Litchfield, 330 F2d 509 (1st Cir. 1964)(13 AFTR2d 1231, 64-1 USTC [paragraph] 9413), aff'g 40 TC 967 (1963). (38) Harold G. McDermid, 54 TC 1727 (1970). (39) Litchfield, note 37. (40) Regs. Sec. 1.213-1(g)(1). (41) Rev. Rul. 75-302, note 32. (42) Sec. 213(a). (43) As was done in Rev. Rul. 78-173, 1978-1 CB 73.
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Author:Sprohge, Hans
Publication:The Tax Adviser
Date:Jul 1, 1993
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