Ferris v. Commissioner

Bonnie Ferris (plaintiff) suffered from a degenerative spinal disorder that made walking and sitting very difficult. Bonnie’s doctor recommended that she and her husband, Collins, build a swimming pool at their house for Bonnie to use twice a day to prevent permanent paralysis. The Ferrises spent approximately $195,000 building a swimming pool that matched their home, a luxury English Tudor-style residence built from hand-cut stone. The estimated market value of the home went from $275,000 to almost $375,000. The Ferrises subtracted purely recreational and entertainment expenses from the cost of the pool and attributed approximately $172,000 of the cost to medical-care expenses. After factoring in the increased value of the house, the Ferrises claimed a deduction of $86,000 for uncompensated medical-care expenses on their joint income-tax return in accordance with § 213 of the Internal Revenue Code. The Commissioner of Internal Revenue (the Commissioner) (defendant) determined that the Ferrises were entitled to deduct a portion of the swimming-pool cost as medical-care expenses but disagreed as to the amount of deduction. The Commissioner argued that the costly building materials used by the Ferrises, as well as the size of the pool, were not medically necessary. The Commissioner concluded that a functionally adequate pool could have been built for $70,000 and limited the Ferrises’ deduction accordingly. The United States Tax Court reversed the Commissioner and held that § 213 imposed no limit on deductible medical-care expenses. The Commissioner appealed.