In reply to .
Yes, I think so.
Obviously, you and your clients want to understand the difference between “reasonable position” and “substantial authority,” carefully look at the facts and circumstances of each individual taxpayer’s practice, etc., to safely apply the Final 199A regs.
Also, not a physician and not a cosmetic surgery patient but my sense is a continuum exists… E.g., someone who does a particular procedure sometimes for pure aesthetic reasons and sometimes for reconstructive reasons? I would think that problematic. Even if on the cosmetic work, no Section 213(d) deduction allowed… On the other hand, someone else who only does something cosmetic-y and something that in some localities doesn’t require a physician? That would seem quite robust.