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the equipment and supplies and some of the travel expenses that
she had claimed were on behalf of fraternal organizations. To
support her claim, petitioner presented various checks, receipts,
and raffle tickets.
Section 170 allows a deduction for charitable contributions
subject to certain limitations. A charitable contribution is the
voluntary transfer of property without adequate consideration.
United States v. American Bar Endowment, 477 U.S. 105 (1986);
Murphy v. Commissioner, 54 T.C. 249, 252 (1970); Urbauer v.
Commissioner, T.C. Memo. 1992-170. Payments to a qualified
charitable organization are deductible as charitable
contributions to the extent that they exceed the fair market
value of any material benefit received in return. United States
v. American Bar Endowment, supra at 118; Murphy v. Commissioner,
supra at 253; Urbauer v. Commissioner, supra.
The checks submitted by petitioner were payment for
admission to various conventions and luncheons held by the
Eastern Star, Cyrenes, Ladies of the Circle of Perfection, and
the Daughters of Isis. Petitioner described these organizations
as "the female side of the Masons" and as fraternal
organizations. A contribution to a domestic fraternal society,
order, or association, operating under the lodge system, is only
deductible if the contribution or gift is to be used exclusively
for religious, charitable, scientific, literary, or educational
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