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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.
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