|
Posted by Dick Adams on June 17, 2008, 5:25 pm
Please log in for more thread options > rdadams@panix.com (Dick Adams) wrote:
>>>> The 501(c)(3) earns 99%+ of its revenues from fees for
>>>> certifying judges and sanctioning competitions which
>>>> it then advertises to its members as volunteer
>>>> opportunities. On the face of it without any additional
>>>> paperwork, are the reasonable travel and lodging expenses
>>>> of the judges deductible as a charitable contribution
>>>> even though the organizers (who rarely make a profit) are
>>>> not 501(c)(3)'s?
>>> So the purpose of your travel is to support the goal of
>>> the 501(c)(3) organization? Do you meet all the criteria
>>> required for deducting charitable travel (e.g. spend
>>> sufficient time each day on the charity's business rather
>>> than your own recreation)? In that case, I'd say it ought
>>> to be deductible.
>> Thank you. What I need is a Circular 230 preparer to write
>> a covered opinion to that extent.
> I've looked into this issue briefly. If the nonprofit
> receives fees for sanctioning the event, and part of that
> is based on supplying qualifying judges, it seems to me
> that the travel expenses may well be deductible.
>
> See Reg. 1.170-2(a)(2)"
>
> "No deduction is allowable for contribution of services.
> However, unreimbursed expenditures made incident to the
> rendition of services to an organization contributions
> to which are deductible may constitute a deductible
> contribution. For example, the cost of a uniform without
> general utility which is required to be worn in performing
> donated services is deductible. Similarly, out-of-pocket
> transportation expenses necessarily incurred in rendering
> donated services are deductible. Reasonable expenditures
> for meals and lodging necessarily incurred while away from
> home in the course of rendering donated services also are
> deductible. For the purposes of this section, the phrase
> while away from home has the same meaning as that phrase
> is used for purposes of section 162."
>
> I think I can find the time to write the opinion for you.
Hopefully, your fee is less than Harlan's. But two letters
are better than one. <g>
Dick
--
<< ------------------------------------------------------- >>
<< The foregoing was not intended or written to be used, >>
<< nor can it used, for the purpose of avoiding penalties >>
<< that may be imposed upon the taxpayer. >>
<< >>
<< The Charter and the Guidelines for submitting posts >>
<< to this newsgroup as well as our anti-spamming policy >>
<< are at www.asktax.org. >>
<< Copyright (2007) - All rights reserved. >>
<< ------------------------------------------------------- >>
| 
Yahoo! 
Google 
Windows Live 
del.icio.us 
digg 
Netscape 
XML Sitemap