- 441 - Unlike the taxpayer in Pepper v. Commissioner, supra, Kanter did not actively solicit financing for his friend Feigan, nor did he or his law firm receive fees for services rendered in the transaction. He merely served as an intermediary to introduce Feigan to another friend, Rappaport. There was no written contract between Feigan and Kanter for the sharing of profits. Accordingly, respondent's determination with respect to this issue is sustained. We hold that Kanter is not entitled to the claimed business loss deduction. We also hold that, because Kanter received no fees and no contract existed therefor, the expenditure did not bear a reasonable and proximate relationship to the production of income. Thus, it is not deductible under section 212. Issue 20. Whether the Kanters Are Entitled To Deduct a Claimed Charitable Contribution of $15,000 to the Jewish United Fund in 1982 FINDINGS OF FACT On their income tax return for 1982, the Kanters listed $25,182 in charitable contributions, which they were unable to deduct on Schedule A as itemized deductions for the reason that the return showed negative gross income of $287,536. The limitation provisions of section 170(b) precluded any deduction for charitable contributions. In the notice of deficiency for 1982, the various adjustments by respondent resulted in the Kanter's having adjusted gross income for 1982 in such amountPage: Previous 431 432 433 434 435 436 437 438 439 440 441 442 443 444 445 446 447 448 449 450 Next
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