## Facts

- A taxpayer residing in Pittsburgh claimed medical expense deductions on his 1945 return that included costs of three trips taken with his wife, who had suffered a serious coronary occlusion in late 1943 and continued to experience chest pain and breathlessness.
- The wife’s cardiologist advised that she would benefit from spending humid summer months at the seashore and winters in Arizona.
- In 1945, the couple took trips to (1) Spring Lake, New Jersey (June 25–July 23), (2) Atlantic City, New Jersey (October 8–October 18), and (3) an Arizona ranch (November 20–December 31).
- The claimed amounts consisted largely of hotel or ranch charges for room and meals, travel, and miscellaneous items (including beverages, cocktails, garage/auto costs, telephone/telegrams, and other incidentals).
- The couple had a history of prior pleasure travel to Atlantic City and Arizona.
- The Commissioner determined a 1945 income tax deficiency of $1,067.60 after disallowing $2,175.83 of claimed medical expense deductions attributable to the travel and related costs.

## Issues

1. Whether expenses for travel, lodging, meals, and incidentals incurred on resort and ranch stays taken for a spouse’s heart condition qualify as deductible “medical care” expenses under I.R.C. § 23(x).
2. Whether such expenditures are instead nondeductible “personal, living, or family expenses” under I.R.C. § 24(a)(1), despite being taken on physician advice.

## Decision

- The Tax Court sustained the Commissioner’s deficiency determination.
- The court held that the travel, room, board, and miscellaneous expenses at the New Jersey resorts and the Arizona ranch did not constitute deductible medical care under § 23(x).
- The disallowed amounts were treated as nondeductible personal or living expenses under § 24(a)(1).

## Legal Principles

- Medical expense deductions are confined to amounts incurred primarily for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for affecting a structure or function of the body.
- To be deductible, an expense must bear a direct or proximate relation to medical care; general health benefits or improved well-being are insufficient.
- Physician recommendation and the taxpayer’s motive are relevant but not controlling; the nature of the expenditure and its medical nexus determine deductibility.
- Travel is deductible only when it is primarily for and essential to obtaining medical services or to the prevention or alleviation of disease, rather than serving as a vacation or personal living expense.

## Conclusion

The court concluded that resort and climate travel—comprised chiefly of ordinary lodging, meals, and vacation-like incidentals—lacked the required direct medical connection and therefore remained nondeductible personal expenses, even if undertaken on medical advice for a serious condition.


Havey v. Commissioner, 12 T.C. 409 (1949)