"Harry" <hh[at]nospam.com> wrote:
- quote -

This clearly implies that if the primary purpose is for the
benefit of the organization rather than personal fulfilment,
that the expenses are deductible.

Stu

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Harry <hh[at]nospam.com> wrote:
- quote -

case. Going to church is a personal expense, but travel to
a church convention MAY be deductible.

Dick

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Harry <hh[at]nospam.com> wrote:
- quote -


- quote -

Wrong, I enjoy beer. I WORSHIP women. Since women are of a
strictly personal nature, the general rule is that there are
no deductions for them - except for alimony and possible HSA
reimbursements for treatment of mental health problems women
have been known to cause. <G
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"Dick Adams" <rdadams[at]smart.net> wrote:

- quote -

I think this is your biggest hurdle...

Code Sec. 170(j) - No charitable deductions are allowed for
travel expenses, including the cost of meals and lodging,
incurred in the course of performing services away from home
for a charitable organization, unless there is no
significant element of personal pleasure, recreation, or
vacation in the travel.

------------------------------- Aram A. Churukian and Marie D. Churukian v. Commissioner,
Expenses--trade or business: Substantiation: Miscellaneous
expenses.--, (June 18, 1980)

Not every incidental expense incurred by a taxpayer in
connection with a charitable activity is deductible.
"Expenses incurred in the rendition of services to a
qualified charitable organization may, and often do, have a
dual character. They may benefit both the charity and the
taxpayer." Seed v. Commissioner [Dec. 31,080 ], 57 T. C.
265, 276 (1971). If the taxpayer or someone other than the
charity derives a substantial and direct benefit which is
personal, the claim for a charitable contribution will not
be allowed.

In the instant case petitioner's performance in the church
choir is a form of religious worship. Religious worship is
fundamentally and inherently a personal act. The manner in
which a person chooses to manifest his or her religious
beliefs during the course of a religious service, whether it
be serving as an usher, performing in the choir or sitting
quietly in the pew, is largely a matter of personal
preference. Any resulting benefit inuring to the church is
largely incidental and does not alter the inherently
personal nature of an act of religious worship. In this
context petitioner's participation in the church is not the
type of service to a charitable organization that is
contemplated by section 170(a) and Treas. Reg. §1.170A-1(g)
.. We conclude that petitioner is not entitled to a
charitable deduction for mileage driven in connection with
his church choir activities.

-------------------------------
Since we know how you worship beer... it seems right on point :-)

H

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Dick Adams <rdadams[at]smart.net> wrote:

- quote -

Contributions to "or for the benefit" of the organization
are deductible, so these should be when it's for the benefit
or convenience of the organization and not the contributor.
E.g. not commuting expenses.

But a brief look into the cases didn't find anything to
help. Sorry. I hope someone else can come up with
something.

Stu

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My reading of Pub 536 leads me to believe organization
members of 501(c)(3) are entitled to charitable deductions
on Schedule A for trnasportation and lodging when they are
acting upon behalf of the organization.

I would appreciate some IRC cites and some courts cites in
support of this.

Dick

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