Davis v. United States
United States Supreme Court
495 U.S. 472 (1990)
The Davises (plaintiffs) deposited money into their sons' checking accounts to support the sons' missionary work for their church, which had internal regulations expecting the accounts to be used solely for missionary purposes, but the sons were under no legal obligation to comply with those regulations; the Davises claimed the deposits as charitable tax deductions, the IRS disallowed them, and after paying back taxes and losing in the district court and Ninth Circuit, the Davises sought Supreme Court review to resolve a circuit split.
Whether, under federal law, a donation to a third party is a tax-deductible charitable contribution only if the third party is legally obligated to use the donation for a charitable organization's sole benefit.