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Angeles area schools we conclude: (1) Some schools charge more
tuition than Emek and Yeshiva Rav Isacsohn, and some charge less;
and (2) the amount of tuition petitioners paid is unremarkable
and is not excessive for the substantial benefit they received in
exchange; i.e., an education for their children. Thus,
petitioners have not shown that any part of their tuition
payments was a charitable contribution, and this case is
indistinguishable from those cited at par. B-2-c.
3. Whether Sections 170(f)(8) and 6115 Authorize
Charitable Contribution Deductions for Tuition Payments
to Schools Providing Religious and Secular Education
Petitioners contend that, under sections 170(f)(8) and 6115
as enacted in 1993, a portion of tuition payments to schools
providing a religious and secular education is deductible as a
charitable contribution.
a. Background
Sections 170(f)(8) and 6115 were enacted under the Omnibus
Budget Reconciliation Act of 1993, Pub. L. 103-66, secs. 13172
and 13173, 107 Stat. 455, to address “difficult problems of tax
administration”8 associated with taxpayers’ deductions of
8 See H. Rept. 103-111, at 785 (1993), 1993-3 C.B. 167,
361, which states in pertinent part:
Difficult problems of tax administration arise
with respect to fundraising techniques in which an
organization that is eligible to receive tax deductible
contributions provides goods or services in
consideration for payments from donors. Organizations
(continued...)
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