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:
“... Washington was not only an important capital. It was a city of fear. Below that glittering and delightful surface there is another story, that of underpaid Government clerks, men and women holding desperately to work that some political pull may at any moment take from them. A city of men in office and clutching that office, and a city of struggle which the country never suspects.”
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