Van Dusen v. Commissioner
United States Tax Court
P incurred unreimbursed volunteer expenses while caring for foster cats in her private residence. P's expenses consisted primarily of payments for veterinary services, pet supplies, cleaning supplies, and household utilities. P claimed a $12,068 charitable-contribution deduction for the expenses on her 2004 tax return. R issued a notice of deficiency denying the deduction.
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P incurred unreimbursed volunteer expenses while caring for foster cats in her private residence. P's expenses consisted primarily of payments for veterinary services, pet supplies, cleaning supplies, and household utilities. P claimed a $12,068 charitable-contribution deduction for the expenses on her 2004 tax return. R issued a notice of deficiency denying the deduction. R claims that P did not render services to a qualifying charitable organization under sec. 170(c), I.R.C., and that P failed to substantiate her expenses under sec. 170(f)(8), I.R.C., and sec. 1.170A-13, Income Tax Regs. R…
1Opinion of the Court
Morrison, Judge:
The Commissioner of Internal Revenue (the IRS) issued a notice of deficiency for the tax year 2004 to petitioner, Jan Elizabeth Van Dusen, determining an income-tax deficiency of $4,838. The parties settled all issues except those relating to a $12,068 charitable-contribution deduction for Ms. Van Dusen’s expenses of taking care of foster cats. 1
We find that taking care of foster cats was a service performed for Fix Our Ferals, a section 501(c)(3) 2 organization that specializes in the neutering of wild cats. See infra part I. Some of Van Dusen’s expenses are categorically not…
2Cases cited19 opinions
- Welch v. HelveringSupreme Court of the United States · 1933
- Cohan v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1930
- Sanford v. CommissionerUnited States Tax Court · 1968
- William F. Sanford v. Commissioner of Internal RevenueCourt of Appeals for the Second Circuit · 1969
- Bond v. CommissionerUnited States Tax Court · 1993
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3Cited by21 opinions
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- Barnes v. Comm'rUnited States Tax Court · 2016
- Feinberg v. Comm'rUnited States Tax Court · 2017
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