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On the morning of February 21, 1990, petitioner flew to
Atlanta, Georgia, for a diocese meeting. Petitioner returned to
his home in Charlotte, North Carolina, later that evening.
Because the trip did not require sleep or rest, petitioner is not
entitled to a deduction for meals on this trip. Accordingly, the
meal expenses claimed in the amount of $25, listed in paragraph
17 of the stipulation of facts, are not deductible. See United
States v. Correll, supra; Saltzman v. Commissioner, supra at 725;
sec. 1.170A-1(g), Income Tax Regs.
Respondent asserts that some expenses were lavish or
extravagant and that some expenses were not required to be paid
by petitioner. Both assertions raise the question whether the
expenses were reasonable and/or necessary. Section 1.170A-1(g),
Income Tax Regs., provides, in relevant part:
Similarly, out-of-pocket transportation expenses necessarily
incurred in performing donated services are deductible.
Reasonable expenditures for meals and lodging necessarily
incurred while away from home in the course of performing
donated services also are deductible.
A requirement of reasonableness is inherent in the concept of
necessary. Boser v. Commissioner, 77 T.C. 1124, 1133 (1981).
Thus, expenses for travel, meals, and lodging must be both
reasonable and necessary. With these guidelines in mind we turn
to petitioner's expenditures for meals, lodging, transportation,
and other travel expenses.
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