Harry T. Cavalaris - Page 21

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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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