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out-of-pocket expenses of $6,586, they were reimbursed $9,539 by
Monroe County, and therefore there are no unreimbursed direct
out-of-pocket expenses for which petitioners are entitled to a
charitable deduction under section 170.
On brief, petitioners concede that they are not entitled to
a deduction for one-fifth of their indirect expenses; i.e., the
fair rental value of their home, vacation cottage, utilities,
etc. Petitioners contend, however, that the $8,559 received from
Monroe County as a board payment reimburses (or partially
reimburses) them for the one-fifth of these indirect costs
attributable to their foster child. Petitioners further contend
that the direct out-of-pocket expenses listed above have only
been reimbursed to the extent of the $509 clothing allowance.
(Petitioners neglect to mention the $471 of special allowances
they received.) Consequently, petitioners claim they are
entitled to a charitable contribution deduction in the amount of
$6,077 for their unreimbursed direct out-of-pocket expenses
($6,586 out-of-pocket expenses - $509 clothing allowance =
$6,077).
In the alternative, petitioners argue that if this Court
finds that they have been reimbursed by a portion of the board
payment for the food expenses of $1,739 directly attributable to
their foster child, they should be allowed a charitable
contribution deduction of $4,338 for the unreimbursed direct out-
of-pocket expenses incurred to care for their foster child
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