A husband and wife, who were members of the Church of Jesus Christ of Latter-day Saints, transferred funds into the personal checking accounts of their two sons.

This expenditure was in line with Church guidelines, which mandated that such funds should only be spent on missionary work and prohibited various leisure or personal activities.

In their 1984 amended federal income tax returns for the years 1980 and 1981, the parents claimed these amounts as deductible charitable contributions.

[2] Additionally, the court determined that the payments did not qualify as "reasonable expenditures" incurred while providing services to the Church, and therefore, they were not deductible under Treas Reg.

Additionally, 26 CFR 1.170A-1(g) did not apply to the parents, as the regulation permits a deduction for unreimbursed expenses by only the taxpayer who performed the charitable service.

Justice O'Connor stated that the legislative history, the generally understood meaning of the language used, and the contemporaneous and longstanding construction all supported this interpretation.

Petitioners were unable to claim a deduction for the funds as unreimbursed expenditures incident to a contribution of charitable services under Treas.