- 10 - respondent placed on the donated items is low, and therefore, find the value of the items donated to Crossnore School to be $500. See Cohan v. Commissioner, 39 F.2d at 543-544. 2. Unreimbursed Travel Expenses As previously noted, section 170(a) allows a deduction for charitable contributions. Section 170(c) requires that a charitable contribution, inter alia, be made "to or for the use of" the charitable organization. No deduction is allowed under section 170 for a contribution of services. However, unreimbursed expenditures made incident to the rendition of services to a charitable organization may constitute a deductible contribution. Sec. 1.170A-1(g), Income Tax Regs. Allowable deductions include transportation expenses and reasonable expenses for meals and lodging necessarily incurred while away from home. Id. The phrase "while away from home" has the same meaning as when used for purposes of section 162. Id. Therefore, a taxpayer's unreimbursed expenses for meals incurred while rendering services are only deductible if the nature of the travel requires the taxpayer to sleep or rest ("sleep or rest rule"). See United States v. Correll, 389 U.S. 299 (1967); Saltzman v. Commissioner, 54 T.C. 722, 725 (1970). A taxpayer making a charitable contribution is required to keep a canceled check, a receipt from the donee organization, or other reliable written record showing the name of the donee, thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011