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Dwayne James is a lawyer, and an active member of First Church. First Church is a party to a zoning appeal. Dwayne travels to the

  1. Dwayne James is a lawyer, and an active member of First Church. First Church is a party to a zoning appeal. Dwayne travels to the state capital, a five-hour drive, to represent the church at the zoning appeal hearing. The hearing finishes late in the day, so Dwayne stays overnight, then drives back the next day. Dwayne charges the church nothing for his services, although his normal billing rate for work of that type is $150 per hour. Is Dwayne allowed a charitable contribution deduction for the donation of his services? If not, can Dwayne realize any tax benefit from these activities?
  2. Jake Bradley is going on a mission trip to South Africa under the auspices of CrossRoads Church Norfolk, of which he is a member. The trip will cost Mr. Bradley several thousand dollars out of pocket for airfare and other trip expenses, unless he is able to raise the funds. Jake's friend, Cookie Douglas, writes a $1,000.00 check, payable to CrossRoads Church, with the notation, "Restricted for costs of Jake Bradley's mission trip." May Douglas deduct this $1,000.00 gift? If not, is there anything that Douglas, Bradley, or CrossRoads could have done differently to make the gift deductible?
  3. Rob Patterson writes a contribution check to Regent University (a 501(c)(3) organization) on November 15, 2017, but forgets to deliver it. He finally remembers, puts the check in an envelope, addresses it to Regent University, and drops it in a mailbox on Sunday, December 31, 2017. Because (i) Patterson lives in Hawaii and (ii) both the U.S. Postal Service and the Regent mailroom are very busy around the holidays, the check is not deposited by the University until Monday, January 8, 2018. Regent's accounting office had closed out its 2017 books on Friday, January 5, and issues Patterson a receipt showing that the gift was made in 2018. Under the Internal Revenue Code and the Treasury Regulations, is Patterson's gift deductible in 2017, 2018, or neither? Why? [Assume that the stated facts can be established; ignore evidentiary questions.]

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