Rev. Rul. 58-279

The taxpayer, an aircraft pilot, performs various services gratuitously for the Civil Air Patrol, an organization of the type described in section 170(c) of the Internal Revenue Code of 1954. He uses his personally owned aircraft, automobile, and other equipment hereinafter mentioned in performing such volunteer services; pays the entire cost of their maintenance and repair; purchases the gasoline and oil used therein, except for fuel and lubricants consumed on `Air Force authorized missions;' and is not otherwise reimbursed for any such expenses. Held, since the organization is a qualified donee under section 170(c) of the Code, the taxpayer may, to the extent of the limitations prescribed in section 170, deduct the nonreimbursed, out-of-pocket expenses directly attributable to the performance of such volunteer services, such as those incurred by the taxpayer for the operation, maintenance, and repair of a personally owned aircraft, automobile, communication system, and telescope, as well as those similarly incurred for the purchase and maintenance of distinctive uniforms which the taxpayer is required to wear while engaged in official Civil Air Patrol activities and is prohibited from wearing except on such occasions. Such expenses are deductible as contributions `for the use of' that organization. Only those expenditures incurred for operation, maintenance, and repair, which are directly attributable to the use of such aircraft, automobile, communication system, and telescope in performing gratuitous services for such organization are deductible. No deduction is allowed for a proportionate share of general maintenance or general repairs of such equipment. Held further , the foregoing principle is not extended to allow a deduction either for the fair rental value of such use, or for the depreciation occasioned by such use, of the aircraft, automobile, communication system, or telescope, in performing volunteer services for the organization. See I.T. 3918, C.B. 1948-2, 33. Furthermore, since liability and property damage insurance carried on a motor vehicle is for the protection of the individual, the premiums paid on such insurance do not qualify as an expense attributable to the use of a vehicle and, consequently, cannot be considered a contribution or gift within the meaning of section 170 of the Code.

For other published rulings on this issue, see Revenue Rulings 55-4, C.B. 1955-1, 291; 56-508, C.B. 1956-2, 126; and 56-509, C.B. 1956-2, 129.