Facts: Your clients, Holly and Greg Orman, are a married couple with two young sons, Blake (age 6) and Jonah (age 4). In late 2014, the Ormans learned that Blake has a medical condition that makes his muscles very weak. In addition to prescribing physical therapy that will include exercises to strengthen Blakes muscles, Blakes doctor suggested that swimming regularly could greatly improve Blakes muscle strength. The Ormans live in a rural area far from any public swimming pool. They are considering installing a swimming pool in the backyard at their house. However, the Ormans would like to know whether the cost of installing a swimming pool may be deductible as a medical expense for federal income tax purposes.

Required:

First Step: Identify and properly cite the Code sections and regulations that discuss the deductibility of medical

expenses. Indicate whether and, if so, where, they indicate whether the cost of a swimming pool may be deductible as a medical expense.

Second Step: Find and review relevant Revenue Rulings that involves the issue of whether the cost of a swimming pool may be deductible as a medical expense. Provide a proper citation for the Revenue Rulings. Briefly describe the facts of the ruling and the IRSs reasoning and conclusion(s). Indicate whether you think the IRS would reach the same conclusion(s) in the Ormans situation and why or why not.

Third Step: prepare an issues memo based on the facts given