IRS Information Letter 2011-0035

IRS Information Letter 2011-0035 is the 2011 IRS letter that most directly addresses gluten-free food costs and celiac disease. It is not binding precedent, which is worth saying first. Information letters are responses the IRS sends to written questions from taxpayers; they do not create new rules and they do not set policy. What they do is record the IRS's understanding of an existing rule when applied to a specific question.

The 2011 letter was a response to a question about gluten-free food costs for a person with celiac. The reply walked the same chain a CPA or tax professional walks today: Publication 502 covers special diets prescribed to treat a medical condition, Revenue Ruling 55-261 is the underlying ruling, and the medical-expense increment for the gluten-free premium is the cost over what a non-gluten-free version of the same food would have cost.

That confirmation is why the 2011 letter matters. It is the most modern public IRS document that addresses the gluten-free premium by name, and it lines up with the older ruling and the booklet. The substantiation chain for a celiac household on Schedule A is consistent across all three sources.

CPAs and tax professionals cite the letter alongside Publication 502 and Revenue Ruling 55-261. The three together carry more weight than any one would on its own.

For the full walkthrough, including how the letter shows up in practice when a return is being prepared, read What Publication 502 actually says about celiac.