Rev. Rul. 54-457

A university provides medical and hospital care for its students, contracting for such care at a stipulated rate per student and paying actual hospital bills for those students hospitalized during the school term. The amount of the fee for the health plan, which is included in the tuition fee charged, is not separately itemized. Held, that if the student pays a lump sum fee which includes his education, board medical care, etc., and no breakdown is made of such fee as to the amount allocable to medical care, no specific part of the tuition fee charged may be considered to be an amount paid for medical care within the meaning of section 23(x) of the Internal Revenue Code of 1939 deductible by individuals in computing net income for Federal income tax purposes. However, if such a breakdown is provided, or is readily obtainable from the university, that portion of the fee charged which is allocated to medical care will constitute a proper deduction under section 23(x) of the Code.