Holding
The payments for auditing or training sessions do not satisfy the "contribution or gift" inquiry necessary for deductibility under IRC ยง170 because it amounted to a quid pro quo for the taxpayer. In other words, the taxpayer received a benefit in consideration for his contribution.
Read more about this topic: Hernandez V. Commissioner
Famous quotes containing the word holding:
“The post-office appeared a singularly domestic institution here. Ever and anon the stage stopped before some low shop or dwelling, and a wheelwright or shoemaker appeared in his shirt- sleeves and leather apron, with spectacles newly donned, holding up Uncle Sam’s bag, as if it were a slice of home-made cake, for the travelers, while he retailed some piece of gossip to the driver, really as indifferent to the presence of the former as if they were so much baggage.”
—Henry David Thoreau (1817–1862)
“But it is the same thing we are all seeing,
Our world. Go after it,
Go get it boy, says the man holding the stick.
Eat, says the hunger, and we plunge blindly in again,
Into the chamber behind the thought.”
—John Ashbery (b. 1927)
“Golf is a fine relief from the tensions of office, but we are a little tired of holding the bag.”
—Adlai Stevenson (1900–1965)