BABILONIA v. COMMISSIONER OF INTERNAL REVENUE

No. 80-7403.

681 F.2d 678 (1982)

Constancio BABILONIA and Cleo Babilonia, Petitioners-Appellants, v. COMMISSIONER OF INTERNAL REVENUE, Respondent-Appellee.

United States Court of Appeals, Ninth Circuit.

Decided July 16, 1982.


Attorney(s) appearing for the Case

Brian J. Seery, Burke, Williams & Sorensen, Los Angeles, Cal., for petitioners-appellants.

Jay W. Miller, Washington, D. C., argued, for respondent-appellee; Robert T. Duffy, Washington, D. C., on brief.

Before ANDERSON, FERGUSON, and REINHARDT, Circuit Judges.


PER CURIAM:

The taxpayers, parents of Olympic figure skater Tai Babilonia, sought to deduct the cost of accompanying Tai to various international competitions as expenses incurred incident to performing a service to a charitable organization. We affirm the Tax Court's decision disallowing the deductions.

We have repeatedly held that donations to a charitable organization are deductible only if made out of a "detached and disinterested generosity." See,...

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