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§9.14 SERVICES(g) Reporting RulesA charity auction is a charitable organization’s fundraising event; it is a specialevent. 359 As such, it is reported on Form 990, Part I, line 9, as a special fundraisingevent (unless Form 990-EZ is used or the organization is exempt from therequirement of filing an annual information return).Line 9a is where the gross revenue from the auction (other than any amountsthe charity is treating as contributions) is reported. Direct expenses are reportedon line 9b. Net income from the event is reported on line 9c. For purposes ofcomputing the $25,000 filing threshold, only the amount of net income need betaken into consideration.§9.14 SERVICESAn individual may contribute his or her services to a charitable organization.This is, of course, the action of a volunteer. A federal income tax charitablededuction is not, however, available for the contribution of services. 360Because the donor of services rarely takes the value of the services intoincome as imputed income, to allow a charitable deduction for the contributionof the services to a charitable organization would be to allow a double deductionunder the circumstances. Also, it is the IRS’s view that the difficulties associatedwith the valuation of services is in itself a policy reason for not allowing thistype of deduction (along with the associated revenue loss).In one case, a lawyer performed legal services for charitable organizationsover a three-year period, for which he was not compensated. For each of theseyears, he deducted amounts reflecting the value of his time expended in renderingthe services. The court involved found the regulation barring the deductionto be valid and held that the lawyer was not entitled to a charitable deductionfor the gift of his time to charity. 361 The court rejected the argument that the lawyerwas donating property: namely, the product of his services in the form ofpleadings, resolutions, opinion letters, reports, deeds, and the like. 362In other instances, the IRS ruled that there is no tax deduction for the gift bya radio station to a charitable organization of broadcast time as part of the station’sprogramming, 363 and that the contribution to a charitable organization bya newspaper of space in the newspaper is not deductible. 364 This rule of lawshould be contrasted with the rule that a contribution of a contract right toreceive purchased services is deductible, because it is not a contribution of thedonor’s services. 365359 See § 23.2.360 Reg. § 1.170A-1(g). The lack of a charitable deduction for the gift of services does not defeat a charitable deductionfor unreimbursed expenditures made incident to the rendering of the services. See § 9.15.361 Grant v. Commissioner, 84 T.C. 809 (1985), aff’d, 800 F.2d 260 (4th Cir. 1986). See also Taylor v. Commissioner,63 T.C.M. (CCH) 2514 (1992); Levine v. Commissioner, 54 T.C.M. (CCH) 209 (1987).362 Even if this regulation (see note 356) did not exist, there nonetheless would not be any charitable deductionfor an amount in excess of basis, because of the rule denying a deduction for an amount in excess of basis forgifts of property created by the donor. IRC §§ 170(e)(1)(A), 1221(3). See § 9.12.363 Rev. Rul. 67-236, 1967-2 C.B. 103.364 Rev. Rul. 57-462, 1957-2 C.B. 157.365 Rev. Rul. 84-1, 1984-1 C.B. 39. 317