Saltzman v. Commissioner
United States Tax Court
The petitioner, the leader of the Harvard-Radcliffe Hillel Folk Dance Group, made two trips by himself to attend folk dance festivals. He later imparted the knowledge acquired on these trips to the members of the Hillel group. Held, the expenses of the trips are not deductible as charitable contributions under sec. 170, I.R.C. 1954.
1Opinion of the Court
OPINION
The issue for decision is whether the petitioner can deduct under section 170 the expenses of his trips to Pittsburgh and to Europe.
Because Hillel is a corporation which qualifies under section 170(c) (2), a contribution or gift “to or for the use of” Hillel is deductible. With respect to a contribution of services, section 1.170-2 (a) (2), Income Tax Regs., provides:(2)' No deduction is allowable for contribution of services. However, unreim-bursed expenditures made incident to tbe rendition of services to an organization contributions to wbicb are deductible may constitute a…
2Cases cited9 opinions
- John Herbert Orr and Elizabeth G. Orr v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Mitchell v. CommissionerUnited States Tax Court · 1964
- Price v. CommissionerUnited States Tax Court · 1987
- Green v. BookwalterDistrict Court, W.D. Missouri · 1962
- Cartan v. CommissionerUnited States Tax Court · 1958
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3Cited by30 opinions
- Seed v. CommissionerUnited States Tax Court · 1971
- Tate v. CommissionerUnited States Tax Court · 1973
- Kurkjian v. CommissionerUnited States Tax Court · 1976
- Van Dusen v. CommissionerUnited States Tax Court · 2011
- Constancio Babilonia and Cleo Babilonia v. Commissioner of Internal RevenueCourt of Appeals for the Ninth Circuit · 1982
25 more not listed; retrieve them via the Exa API.