Education, Business expense or charitable.

[Bird Legs]

Fact: Clients' wife does charitable work with a national 501(c) (3) organization.
The husband works for them & receives W-2. He travels out of state quite frequently in doing this work.
Wife is in the process of preparing a plan of operations etc. in order to set up operations in South America. In preparing for this task she has been out of pocket about $3,300.
in attending seminars, study groups, conferences, etc. in order to prepare her more thoroughly to do this.
This $3,300. was for the seminar fees.
Is there any way this can be deducted on the tax return?
There is an IRS Letter Ruling 8242042 which states."A local scout leader could not deduct the cost of attending a week long training conference for scout leaders because he provided no services via his attendance. While attendance at the conference improved skills which could benefit his local scout organization, he was under no obligation to continue as a local scout leader, and the taxpayer, rather than the local scout group, was held to be the primary beneficiary of the conference."
Need help.
Thanks

[solomon]

Charitable

I would treat it as other out of pocket volunteer expenses - cash contribution.

[OldJack]

I would think that IRS Letter Ruling 8242042 would also apply in this case and her expense would not be a charitable deduction. Her husband being employed with the 501(c)(3) is irrelevant. The charity should have paid for her expenses.

[ChEAr$]

and remember

that letter ruling is a private letter ruling, applicable to one person, the one who asked the question.

[Bird Legs]

Charitable contribution

Thanks to everyone who has responded.
Follow up: I did allow these seminar & workshop fees as a charitable contribution.
Client has already made several trips to Jamaica, representing the Charitable Organization,
as a prelude to the operational manual, as it will apply to Jamaica. The organization
paid for her trips over there. These workshops were to better prepare her for this challenge.

[jainen]

support your position

>>I did allow these seminar & workshop fees as a charitable contribution<<

What did you base this decision on? Bird Legs gave you an opposing citation, which although not a legal precedent is still substantial authority. How do you support your position?

[GIMoe]

Letter ruling

that letter ruling is a private letter ruling, applicable to one person, the one who asked the question.

This may be true, but it is a very good indication on how the agency would rule on a situation of that nature. It set a precedant -- granted, not a legal one -- but a precedant none-the-less. If they ruled this way in that case, chances are very good that they will rule the same way in this one.