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respondent’s determinations denying the deduction for vehicle
expenses with respect to both activities are sustained.
6. Charitable Contributions
Although the issue was not raised by the parties, the Court
has considered the possibility that the deduction for the
business use of petitioners’ home and the vehicle expenses
attributable to the nonprofit activity might be deductible as
charitable contributions.
Taxpayers are allowed a deduction for any “charitable
contribution * * * payment of which is made within the taxable
year” subject to certain limitations. See sec. 170(a)(1). A
charitable contribution includes a contribution or gift to or for
the use of an organization described in section 170(c) (a
qualified recipient). A deduction for the “contribution” of
services is not allowed, but unreimbursed expenditures made
incident to the rendition of services, i.e., transportation
expenses, may be deductible as a charitable contribution. See
sec. 1.170A-1(g), Income Tax Regs.
It is not clear from the record whether the club is a
qualified recipient.4 Assuming that the club is a qualified
recipient, the expenditures nevertheless are not deductible as a
charitable contribution. Petitioners cannot deduct the $100 per
4 Respondent represents that the “activity appears to
involve holding fundraisers for college-bound youth.”
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Last modified: March 27, 2008