- 22 - facts). Petitioner rented the limousine to transport himself and three other executives of AHEPA to and from the airport. Three- fourths of this expenditure is attributable to other individuals and is not deductible. However, respondent also asserts that the rental of a limousine was not a reasonable expense. Petitioner cites Denison v. Commissioner, T.C. Memo. 1977-430, for the proposition that the rental of a chauffeur driven car may constitute a deductible expense. Denison was decided under section 162. We agree that in certain circumstances the rental of a limousine may constitute a deductible expense under section 162, and we do not foreclose the possibility under section 170. However, in Denison, the taxpayers established that the expense benefited their business by impressing wealthy European clients. Petitioner has not shown that the rental of the limousine in Nassau benefited AHEPA, and, indeed, the expense has decidedly personal overtones. See Seed v. Commissioner, 57 T.C. 265, 276 (1971). Accordingly, we hold the rental of a limousine as transportation to and from an airport is not a reasonable expense in the rendition of charitable services. Despite this conclusion, petitioner is entitled to some deduction for transportation to and from the airport. We will allow $40 of the claimed $640 as a deduction for his transportation to and from the airport in Nassau. Cohan v. Commissioner, 39 F.2d at 543- 544.Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 Next
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