Internal Revenue Service
Revenue Ruling

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 Rev. Rul. 67-14

1967-1 C.B. 61

Sec. 170

Sec. 262

IRS Headnote

The amount expended by a tenant for additions or improvements to Government-owned housing is not deductible as a charitable contribution for Federal income tax purposes. Such amount represents a nondeductible personal, living or family expense.

Full Text

Rev. Rul. 67-14

Advice has been requested as to whether the amount expended by a tenant for additions and improvements to Government-owned housing is deductible as a charitable contribution, for Federal income tax purposes.

A civilian employee living in Government-owned housing on a Federal installation is permitted to make permanent additions and improvements at his own expense to the property in which he is living. The improvements are made by the employee for the sole purpose of obtaining additional living comfort and convenience for his family. The employee understands that when completed the additions and improvements will become Government property to which he holds no rights of ownership.

Section 170 of the Internal Revenue Code of 1954 provides, in part, that in computing taxable income there shall be allowed as a deduction, in the manner and to the extent specified, any charitable contribution payment of which is made within the taxable year to or for the use of the United States, but only if the gift or contribution is made for exclusively public purposes.

Since the expenditure was made for the personal comfort and convenience of the employee and his family, such amount is not a contribution or gift to the United States exclusively for public purposes. Such amount represents a nondeductible personal, living, or family expense under section 262 of the Code.

Accordingly, the amount expended by the tenant for additions or improvements to Government-owned housing is not deductible as a charitable contribution, for Federal income tax purposes.