Since the IRS permits deductions for gifts of chattels only after the physical property is delivered, I had been fretted that the valuation on what I had been able to deliver (some mss.

But if the judge should uphold the restrictive agreements and the Hallmark formula there would be no tax liability, Mr. Woods said, because estate-tax law permits charitable deductions up to 100 percent.

The Internal Revenue Service lost cases in which lower courts permitted deductions for expenses incurred by companies in establishing new franchise divisions or opening new branches.

These plans were used heavily since Internal Revenue Code Section 162(m) passed, which permitted deductions for certain performance-based compensation without limitation.

Under the new tax law, which permits deductions only for costs related to work sold, he may deduct only the $1,500 he spent to make the single sculpture among the eight he produced that found a buyer in 1987.

Rather, the question for the Justices was how to interpret a provision in the Internal Revenue Code that permits charitable deductions for contributions made "to or for the use of" a qualified organization.

She said the history of the 1921 provision indicated that Congress had in mind the narrow purpose of permitting deductions for contributions to trusts or foundations that were set up for the support of charitable organizations.

The proper treatment would have been to claim the deductions on their individual Form 1040's, which permit miscellaneous deductions only exceeding 2 percent of income.

The Treasury said today that it would no longer permit such deductions and that the I.R.S. was prepared to bring the matter to court if savings associations failed to abide by it.

He will seek to ensure that these are permitted deductions. (c) Premiums It may be that the headtenant will grant subleases in consideration of a premium and a low rent.