delivered the opinion of the Court.
Wе are called upon in this case to determine whether the funds petitioners transferred to their two sons while they served as full-time, unpaid missionaries for the Church of
I
Petitioners, Harold and Enid Davis, and their sons, Benjamin and Cecil, are members of the Church. According to the stipulated facts, the Church operates a worldwide missionary program involving 25,000 persons each year. Most of these missionaries are young men between ages 19 and 22. If the Church determines that a candidate is qualified to become a missionary, the president of the Church sends a letter calling the candidate to missionary service in a specified geographical location. A follow-up letter from the missionary department lists the items of clothing the missionary will need, provides specific information relating to the mission, and sets forth the estimated amount of money needed to support the missionary service. This amount varies according to the location of the mission and reflects an estimate of the amount the missionary will actually need.
The missionary’s parents generally provide the necessary funds to support their son or daughter during the period of missionary service. If they are unable to do so, the Church will locate another donor from the local congregation or use money donated to the Church’s general missionary funds. The Church believes that having individual donors send the necessary funds directly to the missionary benefits the Church in several important ways. Specifically, it “fosters the Church doctrine of sacrifice and consecration in the lives of its people” as well as reducing the administrative and bookkeeping requirements which would otherwise be imposed upon the Church. App. to Pet. for Cert. 32a.
After accepting the call, the missionary candidate receives priesthood ordinances to serve as an official missionary and minister of the Church. During the missionary service, the mission president (leader of the mission) controls many as
Missionaries receive some supervision over their use of funds. The Missionary Handbook instructs missionaries that “[t]he money you receive for your support is sacred and should be spent wisely and only for missionary work. Keep expenses at a minimum. . . . Keep a financial record of all expenditures.” App. 13. The mission presidents give similar instructions to the missionaries under their supervision. Althоugh missionaries are not required to obtain advance approval of each expenditure they make from their personal checking account, they do submit weekly reports to their group leader listing the amount of time spent in Church service, the type of missionary work accomplished, and a report of the total expenses for the week and month to date. If a missionary begins to accumulate surplus funds, he is expected to take action to reduce the amount of donations sent to him. The mission president may alter his estimates of the аmounts required each month to take into account changing circumstances.
Benjamin and Cecil Davis both applied to become missionaries. In 1979, the Church notified Benjamin by letter that he had been called to missionary service at the New York Mission. A second letter informed him of the estimated amount of money which would be needed to support his service. In 1980, Cecil Davis was notified that he had been called to missionary service at the New Zealand-Cook Island Mission. Cecil also received a second letter informing him about the mission and the amount of money he would need. Petitioners notified their bishop that they would provide the funds requested by the Church to meet their sons’ mission
Petitioners transferred to Benjamin’s personal checking account, on which he was the sole authorized signatory, $8,480.89 in 1980 and $4,135 in 1981. During 1981, petitioners transferred $1,518 to Cecil’s personal checking account, on which he was the sole authorized signatory. Benjamin and Cecil used this money primarily to pay for rent, food, transpоrtation, and personal needs while on their missions. Benjamin also spent approximately $20 per month to purchase religious tracts and other materials used during his missionary work. Neither Benjamin nor Cecil was required to seek or sought specific approval of each expenditure made from his personal checking account. However, each week Benjamin and Cecil submitted a report of the total expenses for the week and month to date. At the end of their service, Cecil had no money remaining in his account; Benjamin had $150 which he used to purchase a camera. (Petitioners do not claim a deduction for this amount.)
In their joint tax returns filed in 1980 and 1981, petitioners claimed their sons as dependents, but did not claim a charitable contribution deduction under 26 U. S. C. § 170 for the funds sent their sons during their missionary service. On April 16, 1984, petitioners filed an amended income tax return for the years 1980 and 1981, claiming additional charitable contributions of the $3,480.89 and $4,882 paid to their sons during the missionary service. In J anuary 1985, the Internal Revenue Service disallowed the refunds. Petitioners filed a refund suit in the United States District Court for the District of Idaho. In September 1986, petitioners filed a second set of amended returns, limiting their charitable deductions to the amounts indicated by the Church and correcting the number of dependents claimed for each year.
In District Court, petitioners and the United States both moved for summary judgment.
The Court of Appeals for the Ninth Circuit affirmed.
Because the Court of Appeals’ decision conflicted with
White
v.
United States,
II
Under § 170 of the Internal Revenue Code of 1954, 68A Stat. 58, as amended, 26 U. S. C. § 170 (1982 ed.), a taxpayer may claim a deduction for a charitable contribution only if the contribution is made “to or for the use of” a qualified organization. This section provides, in pertinent part:
“(a) Allowance of deduction.
“(1) General rule. —There shall be allowed as a deduction any charitable contribution (as defined in subsection (c)) payment of which is made within the taxable year. A charitable contribution shall be allowable as a deduction only if verified under regulations prescribed by the Secretary.
“(c) Charitable contribution defined. — For purposes of this section, the term ‘charitable contribution’ means a contribution or gift to or for the use of—
“(2) A corporation, trust, or community chest, fund, or foundation—
“(B) organized and operated exclusively for religious, charitable, scientific, literary, or educational purposes . . . .” (Emphasis added.)
Petitioners contend that the funds they transferred to their sons’ accounts are deductible as contributions “for the use of” the Church. Alternatively, petitioners claim these funds are unreimbursed expenditures under Treasury Regulation §1.170A-l(g) and therefore are deductible as contributions “to” the Church.
*
We first consider whether the payments
On its face, the phrase “for the use of” could support any number of different meanings. See, e. g., Webster’s New International Dictionary (2d ed. 1950) (“use” defined in general usage as “to convert to one’s service”; “to employ”; or, in law, “use imports a trust” relationship). Petitioners contend that the phrase “for the use of” must be given its broadest meaning as describing “the entire array of fiduciary relationships in which one person conveys money or property to someone else to hold or employ in some manner for the benefit of a third person.” Brief for Petitioners 17. Under this reading, no legally enforceable relationship need exist between the recipient of the donated funds and the qualified donee; in effect, any intermediary may handle the funds in any way that would arguably benefit a charitable organization, regardless of how indirect or tangеntial the benefit might be. Petitioners also advance a second, somewhat narrower interpretation, specifically that a contribution is “for the use of” a qualified organization within the meaning of § 170 so long as the donee has “a reasonable ability to ensure that the contribution primarily serves the organization’s charitable purposes.” Id., at 26. In this case, petitioners argue that their payments at least meet this second interpretation. They point to the Church’s role in requesting the funds, setting the amount to be donated, and requiring weekly expense sheets from the missionaries. The Service, on the other hand, has historically defined “for the use of” as conveying “a similar meaning as ‘in trust for.’” See, e. g., I. T. 1867, II — 2 Cum. Bull. 155 (1923).
Although the language of § 170 would support the interpretation of either the Service or petitioners, the events leading to the enactment of the 1921 amendment adding the phrase “for the use of” to § 170 indicate that Congress had a specific meaning of “for the use of” in mind. The original version of § 170, promulgated in the War Revenue Act of 1917, ch. 63, § 1201(2), 40 Stat. 330, did not allow deductions for gifts “for
It would have been quite natural for Congress to use the phrase “for the use of” to indicate its intent of allowing deductions for donations in trust, as this phrase would have suggested a trust relationship to the members of the 67th Congress. From the dawn of English common law through the present, thе word “use” has been employed to refer to various forms of trust arrangements. See 1 G. Bogert, Trusts and Trustees § 2, p. 9 (1935); Black’s Law Dictionary 1382 (5th ed. 1979)
(“Uses
and
trusts
are not so much different things as different aspects of the same subject. A use regards principally the beneficial interest; a trust regards principally the nominal ownership”). In the early part of this century, the word “use” was technically employed to refer to a passive trust, but less formally used as a synonym for the word “trust.” See Bogert,
swpra,
at 9 (“The words ‘use’ and ‘trust’ are employed as synonyms frequently by writers and judges”); 1 R. Baldes, Perry on Trusts and Trustees §298 (7th ed. 1929) (“A
use,
a
trust,
and a
confidence
is one аnd the same thing . . .”); 1 Restatement of Trusts §§67-72 (Effect of Statute of Uses) (1935). The phrases “to the use of” or “for the use of” were frequently used in describing trust arrangements. See,
e. g., United States
v.
Bowling,
This understanding is confirmed by the Bureau’s initial interpretation of the phrase. It is significant that almost immediately following the amendment of §170, the Commis
The Commissioner’s interpretation of “for the use of” thus appears to be entirely faithful to Congress’ understanding and intent in using that phrase. Moreover, the Commissioner’s interpretation is consistent with the purposes of § 170 as a whole. In enacting § 170, “Congress sought to provide tax benefits to charitable organizations, to encourage the de
Petitioners argue that any interpretation of “for the use of” that requires a qualified donee to have the sаme degree of control over contributed funds as a beneficiary would have over a trust res would make “for the use of” redundant, meaning no more than “to.” We disagree. When Congress amended § 170, it was fully aware of the Bureau’s ruling that the original statutory deduction for contributions “to” a qualified organization could not be claimed for contributions made in trust for the organization. See O. D. 669, 3 Cum. Bull. 187 (1920). Accordingly, Congress amended the statute specifically to overcome this interpretation. Moreover, a contribution made in trust for a charity does not give the charity
Although the Service’s interpretive rulings do not have the force and effect of regulations, see
Bartels
v.
Birmingham,
Although the language of the statute may also bear petitioners’ interpretation, they have failed to establish that their interpretation is compelled by the statutory language. To the contrary, there is no evidence that Congress intended the phrase “for the use of” to be interpreted as referring to fiduciary relationships in general or as referring to a type of relationship that gives a qualified organization a reasonable abil
Viewing the record here in the light most favorable to petitioners, as we must after a grant of summary judgment for the United States, we discern no evidence that petitioners
Ill
Petitioners contend, in the alternative, that their transfer of funds into their sons’ account was a contribution “to” the Church under Treas. Reg. § 1.170A-l(g), 26 CFR §1.170A-l(g) (1989), which provides:
“Contributions of services. No deduction is allowable under section 170 for a contribution of services. However, unreimbursed expenditures made incident to the rendition of services to an organization contributions to which are deductible may constitute a deductible contribution. For example, the cost of a uniform without general utility which is required to be worn in performing donated services is deductible. Similarly, out-of-pocket transportation expenses necessarily incurred in performing donated services are deductible. Reasonable expenditures for meals and lodging necessarily incurred while away from home in the course of рerforming donated services also are deductible. For the purposes of this paragraph, the phrase ‘while away from home! has the same meaning as that phrase is used for purposes of section 162 and the regulations thereunder.”
Petitioners assert that this regulation allows them to claim deductions for their sons’ unreimbursed expenditures incident to their sons’ contribution of services. We disagree. The plain language of § 1.170A-l(g) indicates that taxpayers may claim deductions only for expenditures made in connection with their own contributions of service to charities. Unless there is a specific statutory provision to the contrary, a taxpayer ordinarily reports his own income and takes his own deductions. See,
e. g., Commissioner
v.
Culbertson,
Petitioners’ interpretation not only strains the language of the statute, but would also allow manipulation of §1.170A-1(g) for tax evasion purposes. See Note, Does Charity Begin at Home? The Tax Status of a Payment to an Individual as a Charitable Deduction, 83 Mich, L. Rev. 1428, 1434-1435 (1985);
Brinley
v.
Commissioner,
Petitioners cite judicial decisions that allowed taxpayers to claim deductions for the expenses of third parties who assisted the taxpayers in rendering services to qualified organizations. See,
e. g., Rockefeller
v.
Commissioner,
We conclude that § 1.170A-l(g) does not allow taxpayers to claim a deduction for expenses not incurred in connection with the taxpayers’ own rendition of services to a qualified organization. Therefore, petitioners are not entitled to a deduction under § 1.170A-l(g).
Petitioners also assert that because their sons are agents of. the Church authorized to receive payments to support their
Accordingly, we hold that petitioners’ transfer of funds into their sons’ accounts was not a contribution “to or for the use of” the Church for purposes of § 170. The judgment of the Court of Appeals is
Affirmed.
Notes
The Commissioner has adopted the holding in
Rockefeller
v.
Commissioner,