Josef Abrams

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SUBJECT Josef Abrams

Engagement Issues and Conclusions

Facts Josef Abrams paid $0,000 during the year for his children to attend Jewish schools. Abrams deducted $18,000 on his tax return based on the argument that 60% of his children's instruction was religious and related to the contributions to the temple for conducting its religious functions. He did not deduct the 40% of tuition that was related to secular education. Abrams presented his argument according to the case in which the IRS allowed members of the Church of Scientology to deduct the portion of fees paid to the church that were related to religious education. According to Abrams, a disallowance would constitute unequal application of the law.

Issues Should Mr. Abrams be allowed to deduct the $18,000, or any, that he declares went towards religious functions?Buy Josef Abrams term paper

Authority Section 170 or the IRC defines charitable contributions and general rules that apply. Section 170 (c)()(B) defines a charitable contribution as "organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes."

Rev. Rul. 70-47, 170-1 CB 4. The ruling identifies "pew rents, building fund assessments, and periodic dues paid to a church (an organization described in section 170(c) of the Internal Revenue Code of 154) are all methods of making contributions to the church, and such payments are deductible as charitable contributions within the limitations set out in section 170 of the Code."

Hernandez v. Commissioner 40 U.S. 680 (18). The Supreme Court held on the record presented that payments for auditing to the Church of Scientology were not deductible as charitable contributions because they represented a quid pro quo. The payer was receiving goods or services in return for the payment. The taxpayer in Hernandez had argued that the disallowance of the auditing payments represented an impermissible failure by the IRS to consistently enforce Section 170, relying on various revenue rulings. However, the Supreme Court rejected this contention because the record therein did not support it.

Michael and Marla Sklar v. Commissioner, TC Memo. 000-118, 7 TCM 1815 The Court stated that the value of a gift may be excluded from gross income only if the gift proceeds from a "detached and disinterested generosity" or "out of affection, admiration, charity, or like impulses." However, the Court ruled against Sklar and disallowed the deduction. The payments were identified in the nature of tuition for petitioners children, a personal expense. The payments were mandatory for tuition and therefore not deductible.

Conclusions Josef Abrams should not be allowed to deduct the $18,000 on his tax return. The payments made by Abrams were not made out of detached and disinterested generosity or out of affection, admiration, charity, or like impulses. The payer was receiving goods or services in return for the payment as in Hernandez v. Commissioner. According to Section 170, the contributions must be exclusively for religious purposes and in this case it was not. Along the same lines as Michael and Marla Sklar v. Commissioner, the payments were mandatory as tuition and hence not deductible.

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