Michael and Marla Sklar - Page 24

                                       - 24 -                                         
          substantiate the deduction by obtaining a contemporaneous written           
          acknowledgment of the contribution from the charitable                      
          organization, including an estimate of the value of any goods or            
          services that the charitable organization provided to the                   
          taxpayer.  Under section 6115, a charitable organization that               
          receives a quid pro quo payment in excess of $75 must inform the            
          taxpayer that any charitable contribution deduction is limited to           
          the difference between the value of any money or property                   
          transferred to the charitable organization and the value of any             
          goods or services that the taxpayer received from the charitable            
          organization.                                                               
               Sections 170(f)(8) and 6115 except certain intangible                  
          religious benefits from the substantiation and disclosure                   
          requirements described above.  Sections 170(f)(8) and 6115                  
          provide, inter alia, that if a charitable organization is                   
          organized exclusively for religious purposes and provides solely            
          an intangible religious benefit to a taxpayer in exchange for a             
          payment, the charitable organization need not assign a value to             
          the intangible religious benefit.                                           
                    b.   Petitioners’ Contentions                                     
               Petitioners contend that (1) sections 170(f)(8) and 6115               
          make tuition payments to religious schools deductible to the                
          extent the payments relate to religious education, (2) the                  
          religious education that Emek and Yeshiva Rav Isacsohn provided             






Page:  Previous  14  15  16  17  18  19  20  21  22  23  24  25  26  27  28  29  30  31  32  33  Next

Last modified: May 25, 2011