In Uncategorized on 05/28/2019 at 16:36

This is the third trip to USTC for Robert A. Oliveri, 2019 T. C. Memo. 57, 5/28/19, the flying evangelist. I will skip Judge Colvin’s exposition of the numerous defects in Robert O’s alleged deductions, to focus on a requisite for a trip to evangelize or otherwise spread the good news.

“To be deductible under section 170, a contribution must be ‘to or for the use of’ a charitable organization.  In order to meet this requirement, the expense must be subject to coordination, supervision, or oversight by the organization.” 2019 T. C. Memo. 57, at p. 24. And Judge Colvin quotes The Catwoman, Jan Elizabeth Van Dusen. See my blogpost “The $250 Misunderstanding,” 6/3/11.

Well, Robert O’s outfit, the Brothers and Sisters of the Divine Mercy (BSDM) is a 501(c)(3), and is “…responsible to the Pontifical Council of the Laity, a dicastery of the Catholic Church.  Nothing in the record shows that the Catholic Church recognized or had any formal relationship to BSDM.” 2019 T. C. Memo. 57, at p. 4.

But Robert O’s flying evangelism founders on his logbook (which shows “Training”), his personal expenditures, and the want of a commission from BSDM to go forth to wherever. Like an illustrious predecessor, he needs a commission from his high command to go forth. He doesn’t have it.

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