Sidney Smith paid $30,000 during the year for his children to attend Jewish schools. On his tax return, Mr. Smith deducted $18,000, based on the argument that 60% of his children's instruction was religious and that payments related to that type of instruction constituted contributions to the temple for conducting its religious functions. He did not attempt to deduct the 40% of the tuition that was related to secular education.
Required:
1. Is the $18,000 expense deductible or nondeductible? Including proper citations to relevant authority.