Rev. Rul. 85-53

1985-1 C.B. 71, 1985-17 I.R.B. 5.

ADOPTION EXPENSES; 'SPECIAL NEEDS' CHILDREN

Published: April 29, 1985

Section 222.-Adoption Expenses

  Adoption expenses; 'special needs' children. Under section 222 of the Code, an itemized deduction of up to $1,500 of qualified adoption expenses is permitted for each adopted 'special needs' child.

ISSUE

  Is the $1,500 limitation of section 222(b)(1) of the Internal Revenue Code, relating to the deduction of qualified adoption expenses of a 'special needs' child as defined in section 222(c), a limit on the aggregate amount of the expenses paid or incurred for each adopted child, or a limit on the aggregate amount of all qualified adoption expenses paid or incurred by an individual taxpayer?

HOLDING

  Section 222(b)(1) of the Code limits the deductibility of qualified adoption expenses to an aggregate amount of $1,500 for each 'special needs' child adopted.

Rev. Rul. 85-53, 1985-1 C.B. 71, 1985-17 I.R.B. 5.