Monetary transfers to charitable service providers may be deductible either as charitable contributions or as unreimbursed expenses. Whether a charity must possess the transfer to establish the charity control necessary to effect a charitable deduction is an unresolved issue. Using direct transfers to Mormon missionaries in Davis v. United States as an example, this Note concludes that direct transfers to service providers should be deductible and proposes a test for determining when charity control is sufficient without possession.
David L. Herron,
A Tax Deduction for Direct Charitable Transfers: The Case Against Davis v. United States, 861 F.2d 558 (9th Cir. 1988),
64 Wash. L. Rev.
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