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§ 9.15 UNREIMBURSED EXPENSESand maintaining uniforms, and of maintenance and repair of a telescope)374• Expenses incurred by elected or appointed government officials that aredirectly connected with and solely attributable to the performance of theirofficial duties 375• Expenses incurred in rendering services at and for a church 376• Expenses incurred while rendering services to the American Red Cross asa nurses’ aide (such as local transportation costs and expenses of acquiringand maintaining uniforms) 377• Expenses incurred while assisting underprivileged juveniles selected by acharitable organization (such as admission costs and expenses of meals) 378• Expenses incurred by an individual while participating in a churchestablishedprogram 379• Expenses incurred by volunteer pilots in providing training services foran organization that promotes, fosters, and engages in aviation educationactivities 380There may be as many as six elements of this analysis: (1) whether the activitiesinvolved are exempt functions of the charitable organization; (2) the inherentnature of the services provided; (3) the substance of the services; (4) the durationof the services; (5) whether the outlays are excessive; and (6) the extent of anypleasure derived by the service provider.(a) Exempt FunctionsThus, these expenses, to be deductible, must be directly connected to the performanceof services in enhancement of a charitable organization’s exempt functions.In most of the court opinions and IRS rulings on this subject, this aspect ofthe matter has not been at issue. Nonetheless, even in this area, some aspects ofvolunteer service may entail nondeductible expenses. For example, even thoughexpenses incurred in connection with the rendering of services to a church maybe deductible, the expenses of individuals attending church conventions, assemblies,or other meetings in accordance with their rights, privileges, or obligationsas members of a church are not deductible. 381 Likewise, although unreimbursedexpenses incurred by a volunteer for a charitable organization for the operation,maintenance, and repair of an automobile or airplane may be deductible, itemssuch as the proportionate share of general maintenance and repairs, liabilityinsurance, or depreciation in connection with use of an automobile for charitablepurposes are not deductible. 382374 Rev. Rul. 58-279, 1958-1 C.B. 145.375 Rev. Rul. 59-160, 1959-1 C.B. 59.376 Rev. Rul. 61-46, 1961-1 C.B. 51; Rev. Rul. 56-508, 1956-2 C.B. 126.377 Rev. Rul. 61-46, 1961-1 C.B. 51; Rev. Rul. 56-508, 1956-2 C.B. 126.378 Rev. Rul. 70-519, 1970-2 C.B. 62, modified by Rev. Rul. 84-61, 1984-1 C.B. 39.379 Rev. Rul. 76-89, 1976-1 C.B. 89. See also Rev. Rul. 73-597, 1973-2 C.B. 69.380 Priv. Ltr. Rul. 9243043.381 Rev. Rul. 61-46, 1961-1 C.B. 51.382 Rev. Proc. 82-61, 1982-2 C.B. 849, § 3.01, 1(a), (b). 319

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