Gerald L. and Joy M. Zeidler - Page 7

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          that the determinations are in error.  Rule 142(a); Welch v.                
          Helvering, 290 U.S. 111, 115 (1933).  Moreover, deductions are a            
          matter of legislative grace, and the taxpayer must be able to               
          point to an applicable statute to show that a claimed deduction             
          comes within its terms.  Interstate Transit Lines v.                        
          Commissioner, 319 U.S. 590 (1943).                                          
               Section 170(a) allows as a deduction, subject to the                   
          percentage limitations of section 170(b), any charitable                    
          contribution as defined in section 170(c).  Section 170(c)                  
          provides, in part, that the term "charitable contribution" means            
          a contribution to or for the use of "a corporation, trust, or               
          community chest, fund, or foundation * * * organized and operated           
          exclusively for religious, charitable, scientific, literary, or             
          educational purposes * * * no part of the net earnings of which             
          inures to the benefit of any private shareholder or individual."            
               Petitioners have not satisfied their burden of establishing            
          that the Cantare Chorale singers was an organization exempt under           
          section 501(c), such that contributions thereto would be                    
          deductible under section 170(a).                                            
               Section 1.501(c)(3)-1(b)(1), Income Tax Regs., provides                
          generally that an organization is organized exclusively for one             
          or more exempt purposes only if the "articles of organization"              
          (a) limit the purposes of such organization to one or more exempt           
          purposes, and (b) do not expressly empower the organization to              

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