Smith v. Comm'r
United States Tax Court
Held, petitioner's out-of-pocket expenses (except for a portion of the food, laundry, and camping costs and the repair of an automobile) incurred in preaching, teaching, and otherwise carrying out evangelistic work on behalf of his church are deductible under sec. 170(a), I.R.C. 1954, as amplified by sec. 1.170-2(a)(2), Income Tax Regs.
1Opinion of the Court
FeatheRSTon, Judge:
Respondent determined deficiencies in petitioners’ Federal income taxes for 1967 and 1968 in the respective amounts of $713.81 and $608.39. The issue is whether out-of-pocket expenses incurred by petitioners, while doing evangelistic work in Canada in 1967 and 1968 on behalf of their church and religious faith, are allowable as charitable contribution deductions under section 170.1
FINDINGS OF FACT
At the time this proceeding was commenced, petitioners Travis Smith and Esther J. Smith were legal residents of Peninsula, Ohio. They filed joint Federal income tax returns for…
2Cases cited11 opinions
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Cullinan v. Walker, Collector of Internal RevenueSupreme Court of the United States · 1923
- Seed v. CommissionerUnited States Tax Court · 1971
- John Herbert Orr and Elizabeth G. Orr v. United StatesCourt of Appeals for the Fifth Circuit · 1965
- Mitchell v. CommissionerUnited States Tax Court · 1964
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3Cited by20 opinions
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- Don K. White and Alice S. White v. The United States of AmericaCourt of Appeals for the Tenth Circuit · 1984
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