Rev. Rul. 70-606

An individual who was physically unable to walk and was confined to a wheelchair purchased an automobile that was specially designed for transporting individuals confined to wheelchairs. The vehicle had ramps for entry and exit, rear doors that opened 180 degrees, floor locks to hold wheelchairs in place, and a raised roof giving the required headroom to accommodate wheelchair passengers. The taxpayer paid $6,000 for this specially designed automobile, whereas the cost of a comparable automobile of standard design was $4,500.

Held, since the automobile was specially designed for transporting individuals confined to wheelchairs, the cost to the taxpayer of its special design is a "capital expenditure which is related only to the sick person" within the meaning of section 1.213-1(e)(1)(iii) of the Income Tax Regulations. Accordingly, the amount paid by the taxpayer attributable to the special design of the automobile (that is, $1,500 ($6,000-$4,500)) is a medical expense within the meaning of section 213 of the Internal Revenue Code of 1954 and is deductible in computing taxable income within the limitations of that section.