Harry T. Cavalaris - Page 22

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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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