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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
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