Kingman K. Babcock and Lillian L. Babcock - Page 12

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          encourage his ego development or assist his treatment plan".  For           
          1991, petitioners received the $471 of special allowances for the           
          following expenses (which comprise a portion of the stipulated              
          out-of-pocket expenses under the categories of education and                
          recreation):  Ski program $50; swimming $72; tutoring $240;                 
          parking for jazz dance lessons $109.                                        
               Based on the foregoing, we find that the board payment of              
          $8,559 and the special allowances of $471 reimbursed petitioners            
          for the following out-of-pocket expenses:  Food expenses of                 
          $1,739; education expenses of $150; recreation expenses of $360;            
          and allowance expenses of $102.  We find that the remainder of              
          the board payment reimbursed petitioners, at least partially, for           
          their indirect expenses with respect to their foster child.                 
               For 1991, petitioners also received a clothing allowance of            
          $509, which was a partial reimbursement for the stipulated out-             
          of-pocket clothing expenses of $2,985.                                      
               On this record, we conclude that the following out-of-pocket           
          expenses attributable to petitioners' foster child were not                 
          reimbursed:                                                                 
                    Clothing/toys                 $2,476                              
                    Babysitting                   1,200                               
                    Medical                         50                                
          Total               $3,726                                                  
               In summary, petitioners incurred $6,586 in direct out-of-              
          pocket expenses, and were reimbursed $2,860 for these expenses.             
          Consequently, petitioners are entitled to a charitable deduction            




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