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:
“A Roman divorced from his wife, being highly blamed by his friends, who demanded, “Was she not chaste? Was she not fair? Was she not fruitful?” holding out his shoe, asked them whether it was not new and well made. “Yet,” added he, “none of you can tell where it pinches me.””
—Plutarch (c. 46–120 A.D.)
“One more crack from you, bimbo, and you’ll be holding a lily.”
—James Gleason (1886–1959)
“By 1879, seven churches of various denominations were holding services, which led the local Chronicle to comment, “All have but one religion and one God in common; it is the Crucified Carbonate.””
—Administration in the State of Colo, U.S. public relief program (1935-1943)