12.07.2015 Views

Contents

Contents

Contents

SHOW MORE
SHOW LESS
  • No tags were found...

You also want an ePaper? Increase the reach of your titles

YUMPU automatically turns print PDFs into web optimized ePapers that Google loves.

FUNDAMENTAL CONCEPTS• Merchants and owners of property in a city made (deductible) contributionsto the city to enable it to provide railroad companies with new facilities outsidethe city, in exchange for the railroads’ removal of their inner-city facilitiesand relinquishment of their right of way through the city (even thoughthe merchants and property owners received some benefit from removal ofthe railroad facilities). 119• An organization made (deductible) contributions to a police departmentto assist the department, as a regular part of its operations, in offeringrewards for information leading to the apprehension and conviction ofpersons engaging in criminal activity within the community in which theorganization was located. 120• A parent of a murdered individual made a (deductible) contribution ofreward money to the police department of a political subdivision forinformation leading to the conviction of the murderer, with some or all ofthe money available for public purposes if not needed to pay thereward. 121• An individual made a (deductible) contribution of a tract of land to thefederal government and retained the right during his lifetime to train hishunting dog on the trails extending over the tract. 122• A developer of a residential community made a (deductible) contributionof real estate, tangible personal property, and cash to a state to assist inthe construction of a highway (even though the highway would benefitthe planned community). 123• An individual made a (deductible) contribution of a tract of land and ahouse to an educational organization for a conference and retreat center.The contribution was deductible even though the donor retained anadjoining lot for personal use and a nonexclusive easement for pedestrianand vehicular ingress and egress over the existing driveway on the contributedlot. 124• A member of a federal advisory committee, who incurs unreimbursedtravel and other out-of-pocket expenses while performing services withoutcompensation as a member of that committee, is entitled to a charitablededuction for the expenses as long as the requirements for thededuction are satisfied (“other than those relating to the expectation ofany benefit or financial return”). 125119 Rev. Rul. 67-446, 1967-2 C.B. 119. In this instance, the benefits to the merchants and property owners wereconsidered incidental in comparison to the benefits accruing to the general public. See also Rev. Rul. 79-323,1979-2 C.B. 106; Rev. Rul. 69-90, 1969-1 C.B. 63.120 Rev. Rul. 74-246, 1974-1 C.B. 130.121 Rev. Rul. 81-307, 1981-2 C.B. 78. Again (see note 119), the benefit to the donor was deemed incidental incomparison to the benefits accruing to the general public.122 Rev. Rul. 75-66, 1975-1 C.B. 85.123 Priv. Ltr. Rul. 9447028.124 Priv. Ltr. Rul. 9729024.125 Rev. Proc. 97-52, 1997-2 C.B. 527. 74

Hooray! Your file is uploaded and ready to be published.

Saved successfully!

Ooh no, something went wrong!