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mentioned, petitioners are entitled to deduct unreimbursed
expenditures made incident to the rendition of services to an
organization contributions to which are deductible. Sec. 1.170A-
1(g), Income Tax Regs. In other words, although Congress granted
most foster parents relief from tax recordkeeping in section 131
(as detailed in Cato v. Commissioner, 99 T.C. 633, 641-643
(1992)), if foster parents keep records which show they expended
more than they were reimbursed, they are entitled to deduct the
excess under section 1.170A-1(g). (We note that the New York
State Department of Social Services and Monroe County require
foster parents to keep extensive records concerning their foster
children: "Foster parents are to keep specific financial,
school, health, visitation and child adjustment records/logs".)
Thus, in this case we must decide which expenses have been
reimbursed by the $9,539 petitioners received from Monroe County
to determine the unreimbursed expenses, if any.
The Monroe County Department of Social Services, the agency
responsible for petitioners' foster child, is an organization,
contributions to which are deductible. For 1991, petitioners
received from Monroe County a board payment of $8,559, a clothing
allowance of $509, and special allowances of $471, for a total
reimbursement of $9,539.
Concerning the board payment, the Monroe County Department
of Social Services Foster Parent Manual explains that the
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