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charitable services. This Court held that the parents could
deduct their own unreimbursed expenses and their childrens'
unreimbursed expenses. Both cases were distinguished by the
Supreme Court in Davis v. United States, supra, on the ground
that the parents were being assisted by their children in
rendering the services. Id. at 488. That is clearly not the
situation here.
Rockefeller v. Commissioner, supra, involved the question
whether certain incidental charitable expenses were deductible
under section 170(b)(1)(C) and (g) in effect during the years
1969, 1970, and 1971. These provisions are not involved in this
case, and the holding and reasoning in Rockefeller is inapposite.
We conclude, therefore, that petitioner is not entitled to deduct
expenditures made for meals, a limousine, and registration fees
attributable to other individuals, but we are left with the task
of discerning the portion of those expenses that related to other
individuals.
Petitioner deducted $300 on a trip to Virginia Beach,
Virginia, as registration fees (paragraph 24 of the stipulation
of facts), $175 of which related to registration fees of others
paid by petitioner. Accordingly, we hold petitioner is not
entitled to deduct $175 of these expenses.
Petitioner claimed $640 as a deduction for a limousine on
the Nassau, Bahamas, trip (paragraph 26 of the stipulation of
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