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Respondent determined a deficiency in petitioners' 1991
Federal income tax in the amount of $4,681. The issue for
decision is the amount petitioners are entitled to deduct as a
charitable contribution under section 170 with respect to foster
child care expenses.
Some of the facts in the case have been stipulated and are
so found. Petitioners resided in Pittsford, New York, at the
time they filed their petition.
For clarity and convenience, the findings of fact and
opinion have been combined.
Throughout 1991, petitioners were certified by the Monroe
County Department of Social Services (Monroe County), an agency
of the New York State Department of Social Services (Department
of Social Services), as maintaining a suitable home for the care
and boarding of foster children. The Department of Social
Services describes the issuance of a "Certificate to Board" as
follows:
An authorized child-caring agency -- either the
local department of social services or a private child-
caring agency -- issues a certificate to a family
desiring to board children who are under the care of
the agency, after a home study indicates that the
family meets the [New York State Department of Social
Services'] certification requirements. The agency
supervises the children when they are placed in
boarding care and makes plans for their future, with
their consent and with that of parents and foster
(boarding) parents. The agency is financially
responsible for the needs of the children in foster
care. [Emphasis added.]
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