- 43 - the character of the income as such does not prevent the application of section 265(1). As we stated in Rickard v. Commissioner, supra at 193-194, where the tax exemption attaching to the taxpayer's farm income derived from his status as an Indian and the location of the farm on Indian land: The legislative purpose behind section 265 is abundantly clear: Congress sought to prevent taxpayers from reaping a double tax benefit by using expenses attributable to tax-exempt income to offset other sources of taxable income. Manocchio v. Commissioner, 78 T.C. 989, 997 (1982), affd. 710 F.2d 1400 (9th Cir. 1983). More importantly, the Supreme Court has concluded that Congress intended to limit deductions to those expenses related to taxed income. Rockford Life Insurance Co. v. Commissioner, 292 U.S. 382 (1934). * * * [Fn. refs. omitted.] Nor is it relevant that the tax-exempt income to which FPCF relates was earned by petitioner in an earlier year. In Stroud v. United States, supra, the taxpayer was denied a deduction for amounts paid in the taxable year because of a breach of contract to provide medical service in return for a tax-exempt scholarship received in an earlier year. We hold that the FPCF payments in question are not deductible. Grants to Organizations and for Patient Care Respondent disallowed further deductions for petitioner's grants to charitable organizations because of the limit contained in section 170(b)(2), which provides that a corporation's deductions for charitable contributions may not exceed 10 percentPage: Previous 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 Next
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