Contents

FUNDAMENTAL CONCEPTS• Payments to a charitable organization that operated an adoption agencyin exchange for adoption services 97• Payments to a temple for a bar mitzvah 98• Payments to a museum for lectures, concerts, and exhibitions 99• Payments to a rabbi in connection with the payor’s divorce 100• Expenses of driving children to Girl Scout functions, because the payor’sown children were the principal beneficiaries of the transportation 101• Payments to a school for books and graduation announcements 102• Contribution of property that remained subject to the “donor’s” unrestricteduse and control 103• Payments to a charitable organization when the donor maintained controlover the funds transferred, which went toward personal uses such as subscriptions,dues, and training courses 104• Payments to a charitable organization for tickets to a benefit concert 105• Payments to a charitable organization in exchange for food and drink 106• Ostensible transfer and reconveyance of land between a partnership anda church that was, in general, held to lack economic substance; the transactionconstituted a purchase rather than a gift 107• Payments by parents to a charitable organization that paid their children’stuition; the payors were not allowed to deduct as charitable contributionsthe amounts paid to the organization in excess of the tuitionpayments 108• Payment by individuals to a charitable organization that operated aretirement community, because payment obligated the organization tobuild a cottage for them 109• Payments by a minister to his church (held to be his alter ego), inasmuchas he retained control over the money and property involved 11097 Murphy v. Commissioner, 54 T.C. 249 (1970); McMillan v. Commissioner, 31 T.C. 1143 (1959).98 Feistman v. Commissioner, 30 T.C.M. (CCH) 590 (1971).99 Cogan v. Commissioner, 30 T.C.M. (CCH) 987 (1971).100 Brotman v. Commissioner, 36 T.C.M. (CCH) 279 (1977).101 Hamilton v. Commissioner, 38 T.C.M. (CCH) 775 (1979).102 Ehrhart v. Commissioner, 42 T.C.M. (CCH) 1285 (1981).103 Poldrugovaz v. Commissioner, 47 T.C.M. (CCH) 860 (1984); Odd v. Commissioner, 47 T.C.M. (CCH) 1483(1984).104 Hernandez v. Commissioner, 51 T.C.M. (CCH) 1631 (1986). This case, as developed at the Supreme Courtlevel, is discussed in § 3.1(a)(i), text accompanied by notes 21–24.105 Urbauer v. Commissioner, 63 T.C.M. (CCH) 2492 (1992).106 Edwards v. Commissioner, 64 T.C.M. (CCH) 728 (1992).107 Mount Mercy Associates v. Commissioner, 67 T.C.M. (CCH) 2267 (1994).108 Graves v. Commissioner, 68 T.C.M. (CCH) 1445 (1994).109 Tech. Adv. Mem. 9423001.110 Page v. Commissioner, 58 F.3d 1342 (8th Cir. 1995). 72