8551 / In what year are medical expenses incurred by a taxpayer deductible?

Generally, medical expenses are deductible only in the year they are paid, regardless of when the expenses are incurred. Despite this, in Zipkin v. U.S., expenses incurred by a taxpayer to build a home to meet his wife’s special health needs were properly deducted in the year the home became habitable, even though the costs had been paid in earlier years.¹ Costs paid by parents to modify a van used to transport their handicapped child were deductible in the year those costs were paid; however, the court held that depreciation was not a deductible medical expense.²

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1. 2000-2 USTC ¶ 50,863 (D. Minn. 2000).

2. Henderson v. Commissioner, TC Memo 2000-321.