Question : Tax Research Case

Fly Jones, a U.S. citizen and our client, plays point guard for a professional basketball team, the Wyoming Wildcats. To discourage laziness and mental errors, Fly and his teammates formed the Slammin-Jammin Club on August 30, 2012. Membership in the club was voluntary, but every Wildcat desired to join and did so.

Each time someone on the opposing team blocked a shot during a regular season game, the Wildcat who was "slammed and jammed" paid a $100 fine to the club. When a Wildcat was responsible for a turnover (e.g., having the ball stolen), he paid a $50 fine. Good performance (e.g., blocking the shot of or stealing the ball from an opposing player) did not reduce fines otherwise payable. At the end of the season, the club had collected approximately $40,000.

According to club rules determined at the season''s beginning, one-tenth of the fines was used to fund a barbecue for the players and their families on March 15, 2013. (Fly did not attend the barbecue because his grandmother''s funeral was the same day.) The rest of the funds, again according to previously-determined club rules, were given to the American Red Cross. The Red Cross knew nothing about the contribution until it was actually donated on May 12, 2013. One month later, the American Red Cross sent individual letters of thanks and receipts to each member of the club. The donation amount on each receipt was based on a report the club''s treasurer prepared.

Of the $40,000, Fly contributed $2,200 to the Slammin-Jammin Club in 2012 and $2,800 in 2013. Fly itemizes his deductions. He files jointly, and his adjusted gross income is about $117,000. How much, if any, will Fly be able to itemize as a charitable deduction in 2012 and 2013? Be sure to explain your reasoning with the information from the relevant Internal Revenue Code sections.