Harry T. Cavalaris - Page 10

                                       - 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, the            





Page:  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