Robert and Martha Emanuel - Page 19




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          directly or proximately related to the mitigation or treatment of           
          Christopher’s disabilities and the principal reason for                     
          Christopher’s attendance was to treat his disability.  Therefore,           
          petitioners are entitled to deduct $1,569 in 1996, $1,558 in                
          1997, and $1,234 in 1998 as medical expenses to the extent                  
          allowable under section 213(a).                                             
          2.   Charitable contribution                                                
               Any charitable contribution which is made within the taxable           
          year may be allowed as a deduction.  Sec. 170(a)(1).  Any                   
          contribution of $250 or more shall not be allowed unless the                
          taxpayer substantiates the contribution by a contemporaneous                
          written acknowledgment of the contribution by the donee                     
          organization.  Sec. 170(f)(8)(A).  The written acknowledgment               
          must contain the following information:                                     
               SEC. 170(f)(8)(B) Content of Acknowledgement.– * * *                   
                    (i) The amount of cash and a description (but not                 
               a value) of any property other than cash contributed;                  
                    (ii) Whether the donee organization provided any                  
               goods or services in consideration, in whole or in                     
               part, for any property described in clause (i);                        
                    (iii) A description and good faith estimate of the                
               value of any goods or services referred to in clause                   
               (ii) or, if such goods or services consist solely of                   
               intangible religious benefits, a statement to that                     
               effect.                                                                
               Although no deduction is allowed for a contribution of                 
          services, unreimbursed out-of-pocket transportation expenses                
          incurred, such as mileage driven, while performing donated                  





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