This section contains the nature of the case and procedural background.

Gerard (P) had a daughter that had cystic fibrosis. She needed special diets, medicine, and a special living environment. She was treated with antibiotics and slept in a tent that dispensed them into the air. Because of her illness, it was dangerous for her to be exposed to dry, dusty air. To help, P installed air conditioning in one room but that restricted the child to that room only during the day. Doctors advised that central air would improve her quality of life. P then installed central air at a cost of $1,300. The cost increased the value of the home by $800. The IRS disallowed the deduction.

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