Jane suffers from a degenerative spinal disorder. Her physician said that swimming could help prevent the onset of permanent paralysis and recom- mended the installation of a swimming pool at her residence for her use. Janes resi- dence had a market value of approximately $500,000 before the swimming pool was installed. The swimming pool was built, and an appraiser estimated that the value of Janes home increased by $98,000 because of the addition. The pool cost $194,000, and Jane claimed a medical expense deduction of $96,000 ($194,000 - $98,000) on her tax return. Upon audit of the return, the IRS determined that an adequate pool should have cost $70,000 and would increase the value of her home by only $31,000. Thus, the IRS claims that Jane is entitled to a deduction of only $39,000 ($70,000 - $31,000).

a. Is there any ceiling limitation on the amount deductible as a medical expense? Explain.

b. Can capital expenditures be deductible as medical expenses? Explain.

c. What is the significance of a minimum adequate facility? Should aesthetic or ar- chitectural qualities be considered in the determination? Why or why not?