Rev. Rul. 67-76

Revenue Ruling 58-8, C.B. 1958-1, 154, deals with the deductibility, as a medical expense under section 213 of the Internal Revenue Code of 1954, of the cost of a three-wheel motor vehicle commercially known as an `autoette,' acquired by a totally disabled taxpayer for his personal transportation. As a modification of a prior position, that Revenue Ruling holds that where a person who is sick or disabled acquires an `autoette,' or a wheelchair, either manually operated or self-propelled, and uses it primarily for the alleviation of his sickness or disability and not merely to provide transportation between his residence and place of employment, the cost of the `autoette,' or the wheelchair, constitutes an allowable medical expenses under section 213 of the Code. However, that Revenue Ruling did not discuss the tax treatment of operating and maintenance costs.

Held , the cost of operating and maintaining an `autoette,' or a wheelchair, used primarily for the alleviation of sickness or disability and not merely to provide transportation between the user's residence and place of employment, also is deductible as a medical expense under section 213 of the Code.

Revenue Ruling 58-8 is hereby amplified.