Kingman K. Babcock and Lillian L. Babcock - Page 6

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          Lansing, New York; fair rental value of all furnishings in their            
          home and cottage; fair rental value of their 2-week use of a                
          condominium at Sanibel Island, Florida; fair rental value of                
          petitioners' boat, sailboat, and waverunner; utilities;                     
          landscaping and repair expenses; country club dues and expenses;            
          and automobile mileage for family trips.  The sum of these items,           
          as initially computed by petitioners, was $123,507.  One-fifth of           
          this equaled $24,701.                                                       
               Next, petitioners added actual out-of-pocket expenses                  
          attributable to their foster child for 1991.  These included the            
          following:  Food expenses directly attributable to their foster             
          child; clothing/toys purchased; educational expenses; babysitting           
          expenses; medical expenses; recreation expenses; and the                    
          allowance given to their foster child.  The sum of these out-of-            
          pocket expenses, as initially calculated by petitioners, was                
          $6,438.  The total for both the indirect and out-of-pocket                  
          expenses was $31,139.                                                       
               Petitioners then reduced the amount of the indirect and out-           
          of-pocket expenses by the $9,539 they received from Monroe                  
          County.  This left an interim amount of $21,600.                            
               Last, petitioners reduced the $21,600 by $6,499.  This                 
          resulted in the $15,101 charitable contribution deduction claimed           
          on their 1991 return for foster care expenses in excess of                  
          reimbursement.                                                              






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